CBAM definitive period begins: 2026 imports now carry a financial obligation

What happened

The EU's Carbon Border Adjustment Mechanism (CBAM) moved to its definitive period on 1 January 2026, after a reporting-only transitional period that began in October 2023. According to the European Commission, the definitive regime applies from 1 January 2026.

Core elements of the definitive period:

• Authorised declarant: EU importers (or indirect customs representatives) that import CBAM goods above the annual mass threshold of 50 tonnes must obtain authorised CBAM declarant status. The threshold was introduced by the simplification regulation published in October 2025.
• Annual declaration and surrender: Each year, importers declare embedded emissions and surrender the corresponding number of CBAM certificates. The first declaration and surrender, for 2026 imports, are due by 30 September 2027; certificate sales can start on 1 February 2027.
• Certificate price: Linked to the EU ETS auction price; a quarterly average is used for 2026 and a weekly average from 2027.
• Default values and benchmarks: Default values for the definitive period were set by Implementing Regulation 2025/2621, and benchmark values for the free allocation adjustment by Implementing Regulation 2025/2620. Errors in the default values were corrected in July 2026 by Implementing Regulation 2026/1740.
• Verification: Verification principles and verifier accreditation are governed by separate implementing and delegated regulations.

The financial obligation under CBAM will rise in step with the gradual phase-out of free allocation in the EU ETS through 2034.

Who is affected

Turkish companies exporting iron and steel, aluminium, cement, fertilisers, hydrogen and electricity to the EU. Although the obligation lies with the importer in the EU, the embedded emissions data that determines the cost comes from the Turkish producer. For suppliers that cannot provide actual, verified data, the importer has to use the default values published by the Commission; because these values do not reflect an installation's actual performance, they can work against efficient producers. Verified emissions data has therefore become a direct competitive factor in price negotiations.

What companies should do

• For every product shipped to the EU in 2026, calculate embedded emissions at installation and product level and share them with your buyer.
• Plan verification of your 2026 data with a verifier accredited for the CBAM method.
• Calculate the gap between default and actual values and use it in commercial negotiations.
• If you are covered by the ETS in Türkiye, keep the data sets for both systems in a single infrastructure.

Alalëa supports embedded emissions calculations, verification readiness and buyer communication: CBAM readiness.