Mr. Lang stated that the final phase of CBAM, which began on January 1, 2026, transformed this mechanism from a reporting mechanism into a financial mechanism for importers. CBAM costs are currently actively increasing, and importers must account for these costs during 2026, as failure to do so shifts the financial burden to other parts of the supply chain.
Default values significantly increase costs
A CarbonChain representative highlighted a key element that represents a significant cost difference between the default values and the verified actual emissions data. The default values, which are based on EU-published average emissions figures by product (CN code), production route, and country, are often punitive in nature. He stated that the gap between standard and actual emissions could reach two to four times the cost, especially for products shipped from countries such as China, India and South Africa.
The CBAM cost mechanism is designed to reflect the EU Emissions Trading System (ETS), with the aim of ensuring a level playing field. Emissions exceeding the reference levels are fully subject to CBAM fees, and the benchmarks are reduced annually in accordance with the phase-out of free ETS quotas. As a result, the cost risk starts from the first year and increases over time.
He gave an example showing a steel roll replacement plant with an emission intensity of 1.343 TCO₂/t compared to a reference value of 0.782 tco₂/t, resulting in an estimated cost of approximately 46.42 euros per ton, assuming the ETS price is 80 euros/t.
Strict deadlines for compliance
Mr. Lang stated that the deadlines for compliance are clearly defined. During the monitoring year 2026, operators must collect emission data throughout the year, prepare emission reports in the first quarter of 2027, and receive third-party verification by the second quarter of 2027. Importers should start purchasing CBAM certificates on February 1, 2027, with prices for certificates based on the average quarterly ETS price. The deadline for submitting CBAM declarations and 2026 emission certificates is September 30, 2027.
Starting out
