CBAM 2026: what the carbon tariff is and how it affects your business

‍January 2026 marked a turning point for thousands of importing companies across Europe. The Carbon Border Adjustment Mechanism, known as CBAM, stopped being a distant warning and became a real financial obligation. If your company imports certain materials from outside the EU, this already affects you.

In this article, we explain what CBAM is, how it works, who is required to comply, and how rigorous carbon footprint management can make a real difference.

What is CBAM and why does it exist?

CBAM is the European Union’s climate policy instrument designed to put a price on the carbon emitted during the production of emissions-intensive goods entering the EU market from third countries. It is regulated by Regulation (EU) 2023/956, adopted in May 2023.

Companies producing within the EU already pay for their emissions through the Emissions Trading System (ETS). A manufacturer in China, Turkey, or India exporting to Europe, by contrast, did not bear the same environmental cost. This created a double distortion: unfair competition for European industry and a perverse incentive to relocate production—known as carbon leakage.

CBAM corrects this asymmetry by leveling the playing field and encourages cleaner industrial production worldwide, not just within the EU.

From the transitional phase to the definitive phase

CBAM has been introduced gradually:

• October 2023 – December 2025 (transitional phase): importers were required to report the embedded emissions in their imports, but no payments were due. This was a learning period for companies and authorities to understand how to measure and declare emissions.
• From January 1, 2026 (definitive phase): real financial obligations begin. Importers must purchase CBAM certificates equivalent to the tonnes of CO₂ embedded in the goods they place on the EU market.

The first annual declaration, including the surrender of certificates, must be submitted before September 30, 2027, covering imports made in 2026.

Which sectors are affected?

In its initial phase, CBAM covers six carbon-intensive industrial sectors:

• Iron and steel (including downstream products such as fasteners or prefabricated structures)
• Aluminum
• Cement
• Fertilizers
• Hydrogen
• Electricity

Once fully implemented, these sectors will account for more than 50% of the emissions covered by the EU ETS. The European Commission is mandated to review and expand the scope of CBAM, meaning sectors such as plastics, chemicals, or other carbon-intensive consumer goods could be included in the coming years.

How does the mechanism work?

CBAM operates in three steps:

1. Measure embedded emissions‍

For each imported good, the amount of CO₂ emitted during its production in the country of origin is estimated. If the supplier does not provide a report verified by an independent body, the calculation is based on default values published by the European Commission. These are conservative and usually assign higher emissions than real data.

2. Declare and purchase certificates‍

Authorized importers must annually declare the embedded emissions and acquire the corresponding number of CBAM certificates. The price of these certificates reflects the EU ETS carbon price: in 2026 it is set quarterly as the average auction price; from 2027 onwards, it is set weekly.

3. Deduct what has already been paid‍

If the foreign supplier has already paid a carbon price in the country of origin, that amount can be deducted from the CBAM cost. This incentivizes exporting countries to develop their own carbon pricing systems.

Who is required to comply? The 50-tonne threshold

Not all importing companies are affected in the same way. In 2025, the European Commission simplified the rules by introducing a single annual threshold of 50 tonnes: companies importing less than this amount of CBAM goods (across all sectors, except electricity and hydrogen) are exempt from the mechanism’s obligations.

This threshold covers around 90% of European importers, although it represents only about 1% of actual emissions.

If you exceed 50 tonnes, you must apply for authorized CBAM declarant status with the competent authority in your country. In Spain, the relevant body is the Spanish Tax Agency (AEAT).

The real cost: an illustrative example

For a regular importer of steel profiles from China, CBAM can add between €80 and €250 per tonne, depending on the weekly EU ETS price.

The basic formula is:

CBAM cost = Imported tonnes × Embedded emissions (tCO₂/t product) × ETS price (€/tCO₂)

This cost will gradually decrease as the free allocation of emission allowances still granted to EU installations is phased out—through a CBAM adjustment factor that will progressively decline until disappearing in 2034, when CBAM will be fully in force.

Why emissions management is no longer optional

CBAM has a clear consequence for any company that buys or sells carbon-intensive materials: measuring your emissions accurately saves you money. If you don’t obtain verified data from your suppliers, you’ll pay based on default values—which are always higher than reality. The more precise your carbon footprint data, the lower your CBAM cost.

In addition, reducing your carbon footprint brings direct economic benefits beyond CBAM: lower operating costs, stronger positioning with investors and clients, and greater resilience to future regulations.

This is directly connected to what we do at Manglai: our platform enables precise calculation of Scope 1, 2, and 3 emissions (including product and supply chain footprints), manages supplier data through structured surveys, and generates auditable reports with full traceability. All of this is powered by AI that automates up to 90% of data collection and processing.

In an environment where the cost of poor measurement is already financially tangible, having a robust environmental management tool is no longer a competitive advantage—it’s an operational necessity.

CBAM within the broader regulatory landscape

CBAM does not operate in isolation. It is part of a growing European regulatory ecosystem that includes the Corporate Sustainability Reporting Directive (CSRD), the Real Decreto 214/2025 on carbon footprint in Spain, the EU Taxonomy Regulation, and the European Sustainability Reporting Standards.

Companies that are already managing their carbon footprint systematically have a real advantage when it comes to meeting CBAM requirements, as much of the necessary data is already integrated into their management systems.

Want to understand how CBAM affects your business and what carbon data you need to have ready?‍

Request a personalized demo.