From 2026, eligible EU importers covered by the definitive Carbon Border Adjustment Mechanism (CBAM) must account for embedded emissions in specified products and surrender certificates after relevant adjustments. Choosing actual verified emissions rather than European Commission default values can affect their calculated obligations and the competitiveness of imported goods. The European Commission’s August 2026 sector guidance sets out production boundaries, precursor treatment, monitoring requirements and calculation methods.
The first annual declaration for imports made in 2026 is due by 30 September 2027. An importer sourcing from a relatively clean steel mill, aluminium smelter or fertiliser plant may benefit from establishing the producer’s actual emissions intensity if the applicable default value is unfavourable. But a supplier’s environmental claim alone is not enough: actual values must meet detailed methodology and verification requirements.
Production routes can result in significantly different emissions profiles for steel and aluminium, making the quality of installation data commercially consequential. Default values can simplify administration, but may conceal the advantage of efficient equipment or lower-carbon energy. A properly supported actual-value claim may lower a calculated obligation, while requiring evidence that production and precursor data are complete and allocation is consistent.
Electricity claims require specific evidence
The Energy Community Secretariat reported that imports of electricity from non-EU neighbours faced significant obstacles in the first quarter of 2026. One obstacle was the use of country-level default factors even when exported electricity had been generated by hydropower.
Claims using actual electricity emissions are subject to conditions on contracts, grid connections, congestion and physical scheduling. A generator’s renewable label or guarantee of origin alone does not establish eligibility to use actual emissions values. Importers therefore need to establish that supporting evidence meets the applicable conditions, rather than relying only on the source of the electricity.
Documentation shapes procurement decisions
Importers should secure contractual rights to emissions documentation, verifier access and correction of errors before becoming dependent on a supplier. They should also keep a defensible reconciliation between customs quantities and the emissions data attributed to the goods. Incomplete evidence may mean both a higher carbon-related liability and an inability to explain that liability to the EU industrial customer that ultimately pays.
Supplier comparisons are meaningful only when they use the same customs product and technical specification, verified emissions methodology, origin and production period. Better emissions data can inform supplier selection, investment in cleaner production and price negotiations, extending its management implications beyond tax compliance.