From 2026, eligible declarants under the definitive EU Carbon Border Adjustment Mechanism (CBAM) must account for emissions embedded in specified products and surrender certificates after relevant adjustments. Choosing actual verified emissions or European Commission default values can affect calculated obligations and the competitiveness of imports.
The European Commission’s August 2026 sector guidance covers production boundaries, precursor treatment, monitoring requirements and calculation methods. The first annual declaration for imports made in 2026 is due by 30 September 2027.
Actual-value claims require compliance with detailed methodology and verification requirements, not an unsupported environmental claim by a supplier. Importers sourcing from a relatively clean steel mill, aluminium smelter or fertiliser plant may have reason to establish actual emissions intensity rather than rely on an unfavourable default. Different production routes can create significantly different emissions profiles for steel and aluminium, making installation data quality commercially consequential.
Electricity claims face specific conditions
The Energy Community Secretariat reported that power imports from non-EU neighbours faced significant obstacles in the first quarter of 2026. Among them was the use of country-level default factors even when exported electricity had been generated by hydropower.
Claims based on actual electricity emissions are subject to conditions concerning contracts, grid connections, congestion and physical scheduling. A generator’s renewable label or guarantee of origin alone does not establish eligibility to claim actual emissions values.
Evidence affects supplier and cost decisions
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 also exposing missing production records, unverified precursor data or inconsistent allocation.
Importers should secure contractual rights to documentation, verifier access and correction of errors before becoming dependent on a supplier. They should also maintain a defensible reconciliation between customs quantities and emissions data attributed to the goods.
Meaningful supplier comparisons require the same customs product and technical specification, verified emissions methodology, origin and production period. Better emissions data can support supplier selection, investment in cleaner production and price negotiations, extending its management relevance beyond tax compliance. Incomplete evidence can mean both a higher carbon-related liability and an inability to explain that liability to the EU industrial customer that ultimately pays.
