The European Commission has published updated guidance on the Carbon Border Adjustment Mechanism (CBAM), clarifying key requirements for importers as the regulation has reached the point of full implementation on 1 January 2026.
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CBAM is the EU’s mechanism for placing a carbon cost on selected imported goods. It is designed to prevent carbon leakage—where tighter EU carbon pricing leads to production shifting to countries with lower regulatory standards. From 1 January 2026, all importers bringing CBAM-covered goods into the EU must be registered as authorised CBAM declarants.
A 50-tonne annual import threshold will apply to most goods covered by the mechanism. Hydrogen and electricity imports remain exempt from this limit.
The first annual CBAM declaration will be due by 30 September 2027, covering the full 2026 reporting year. CBAM certificates—which importers must purchase to account for the embedded carbon emissions in their goods—will be available from 1 February 2027. From 2027 onwards, authorised declarants will also be required to hold a minimum number of certificates each quarter.
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The updated guidance places increased emphasis on the use of verified emissions data at the installation level, reflecting the EU’s focus on how and where imported goods are produced. Importers may still rely on default emissions values where verified data is unavailable. The Commission has confirmed that these defaults carry mark-ups. Using them is not cost-neutral and should not be treated as a straightforward alternative to verified data.
The guidance also confirms that authorised declarants bear full legal responsibility for the accuracy of their declarations. This applies regardless of whether emissions data is sourced from the declarant, their suppliers, or third parties.
Read more: EU draft rules recognise Paris Agreement credits under CBAM
The Commission’s updates form part of broader preparations for CBAM’s full launch across EU industries. The mechanism is designed to ensure that imported goods carry a comparable carbon cost to EU-produced goods, as Europe continues to strengthen its domestic carbon pricing framework.
As compliance frameworks like CBAM put quality and credibility at the centre of carbon pricing, the integrity of the credits behind every claim matters more than ever. Green Earth develops large-scale, nature-based carbon projects accredited by leading international standards, with full oversight of every stage of the project lifecycle—from design and implementation to long-term monitoring and credit issuance. Our projects restore ecosystems, enhance biodiversity, and improve community livelihoods, delivering verified environmental impact that stands up to scrutiny. For businesses navigating an evolving regulatory landscape, that integrity is what counts.
