CBAM 2026: What changes with the start of implementation?
Following the transitional phase from 2023 to 2025, the CBAM start 2026 establishes binding compliance requirements for EU importers of carbon-intensive goods. CBAM is now fully integrated into EU customs procedures and becomes part of standard import processes across the Union.
Although the CBAM definitive regime starts on 1 January 2026, the financial settlement through CBAM certificates will apply from 2027 onwards.
As of January 2026, CBAM obligations apply at an operational level:
- Importers must hold authorised CBAM declarant status
- CBAM checks are integrated into EU customs clearance systems
- The 50-tonne de minimis threshold applies for most CBAM-covered goods
- Emissions and carbon data must be available and reportable at import
CBAM therefore shifts from a preparatory reporting exercise to an enforced compliance mechanism, affecting customs, data management, and supply-chain transparency.
Emissions data and reporting obligations
Importers must submit annual CBAM declarations covering imported goods and their embedded carbon emissions. Reliable emissions and carbon data from suppliers in third countries becomes increasingly important, as compliance is assessed based on declared information submitted through the CBAM registry.
Where available, verified emissions data helps reduce reliance on conservative assumptions and supports cost-efficient compliance.
CBAM default values 2026
If supplier-specific emissions data is unavailable, CBAM default values may be applied. These default values are intentionally conservative and typically reflect high emission intensities.
As a result, companies relying on default values may face higher carbon-related costs in the future, creating a strong incentive to establish structured data collection and supplier engagement processes during 2026.
Customs, authorization and compliance controls
Only authorised CBAM declarants are permitted to import CBAM-covered goods into the European Union. CBAM compliance is validated through integrated customs workflows, increasing transparency and regulatory oversight.
Non-compliance can lead to penalties, increased scrutiny by national authorities, and disruptions to import processes.
Impact of the CBAM operational phase on companies and importers
The implementation of CBAM in 2026 significantly increases the operational and compliance burden for affected companies:
- Greater need for emissions, carbon and product data management
- Increased supplier engagement and data verification efforts
- Integration of CBAM data into customs, taxation and reporting processes
- Strategic implications for sourcing, pricing and supplier selection
Companies that prepare early and establish robust emissions management processes gain a clear advantage, while those relying on incomplete data face elevated compliance and cost risks.
Outlook: What changes with CBAM in 2027?
While CBAM is operational from 2026, financial obligations take effect from 2027.
From 2027 onwards:
- Importers must purchase and surrender CBAM certificates
- Certificates will cover embedded emissions from goods imported in 2026
- Certificate prices will be linked to EU ETS allowance prices
- Financial exposure will depend directly on emissions data quality
This means 2026 is the critical preparation year. Companies that invest early in accurate emissions data, supplier collaboration and digital processes will be better positioned to control costs once CBAM certificate payments apply.
CBAM and IPOINT Carbon Footprint Solutions
Managing CBAM requirements requires accurate emissions calculation, transparent data management and regulatory compliance across global supply chains.
IPOINT’s Carbon Footprint solutions support companies in preparing for CBAM 2026 by enabling:
- Collection and management of supplier-specific emissions data
- Calculation of embedded carbon emissions at product level
- Structured reporting aligned with EU CBAM rules and customs requirements
- Integration with broader carbon, compliance and sustainability strategies
With CBAM evolving into a permanent carbon pricing mechanism, digital solutions are essential to ensure data quality, reduce compliance risks and prepare for the financial obligations starting in 2027.