The EU Carbon Border Regulation Mechanism (CBAM) entered its formal period on January 1 this year. On September 28, the European Commission issued supporting documents such as inspectors 'guidelines and registration procedures.This mechanism has changed from a "legal text" to a "working infrastructure"。For steel, aluminum and their products export factories, the bills in 2026 are still small, but the bills for 2026 will have to be paid in 2027, and the coverage will be extended to downstream products in 2028. Now, the cost of replenishing data and changing contracts is the lowest; when customers use carbon data to lower prices, they will be passive.
Where did CBAM go: a timeline to understand
- January 1, 2026:At the beginning of the official period, EU importers have changed from "reporting only data" to "paying for certificates to purchase", covering six major categories of steel, aluminum, cement, fertilizer, hydrogen, and electricity and their products;
- Starting from September 2026:Verification agencies began to apply for access to the CBAM registration system, and the European Commission issued guidelines for verification and recognition-EU buyers can already select verifiers and force suppliers to submit measured data;
- February 1, 2027:CBAM certificates are sold on the EU unified platform, and the certificate price is linked to the EU Carbon Market (EU ETS) quota auction price;
- Before September 30, 2027:EU importers completed their first declaration and certificate settlement in 2026-the first real carbon bill fell on this day.
2. Calculate the account first: What is the carbon cost of one ton of goods
Certificate price reference: CBAM certificate price anchors the average EU ETS auction price in the first quarter of 2026, approximately75.36 EUR/ton of carbon dioxide。The actual cost depends on two variables-the implied carbon emissions of the product and the origin of origin. Taking stainless steel cold rolled coils as an example, professional organization SMM estimates:For the same CN code (304 cold rolling), the corresponding CBAM bills for different producing areas range from approximately € 185 to € 626 per tonThe carbon cost of 304 cold rolled coils produced in Indonesia entering the EU is about 626 euros/ton. Source:Release Notes for SMM Stainless Steel CBAM Calculator (October).
Two buffers make the actual bill in 2026 less scary: First, only 2.5% of implied emissions will be paid in 2026 (corresponding to the proportion of free quotas still enjoyed by EU producers), and will be increased year by year until the full amount will be reached in 2034; Second, from the official period, indirect emissions of steel and aluminum (emissions from electricity consumption) will no longer be declared or counted in settlement. However, the buffer is "late delivery" not "exemption", and the cost trend is deepening year by year.
3. The 50-ton threshold and two key rules
- Annual threshold of 50 tons:Each EU importer who imports no more than 50 tons of CBAM goods per year can be exempted from all obligations. This threshold exempts about 90% of importers (but still covers about 99% of emissions). Whether your EU customer is the "90% exempt" directly determines whether he will come to you for carbon data-ask first.
- Smelting and casting country declaration linkage:Starting from October 1, EU importers must provide material certificates containing the smelting and casting country and furnace batch numbers when applying for steel products. Starting from October 2027, the smelting and casting country will also be included in the quota allocation reference. Carbon data and origin traceability are being merged into a set of "upstream transparency" requirements.
- There is a large gap between the measured value and the default value:When verified measured data cannot be provided, EU importers can only declare using default values, which are usually significantly higher. For the same type of product, the measured value path may save about 60% of the carbon cost compared to the default value path-data power is bargaining power.
4. Four things the factory needs to do now
- The first thing: classify buyers according to thresholds.List a list of EU customers and confirm one by one whether the annual import volume exceeds the 50-ton threshold. Buyers who exceed the threshold will have to pay in 2027. They are the most anxious now, and they are the first to come to you for data-give priority to serving these customers.
- The second item: Establish emission data accounts.Starting from your own process, compile basic data such as fuel consumption, raw material consumption, and product output, and try to calculate implied emissions according to the CBAM accounting method. Enterprises with conditions introduce third-party verification, and the measured data is valid for five years and can serve multiple EU buyers.
- The third item: Pull precursor data upstream.The carbon cost of downstream products must add up the emissions of precursors such as crude steel, steel coils, and aluminum ingots. It is much faster to ask steel mills and aluminum factory suppliers to provide emission data or written explanations now than to go temporarily.
- Fourth: Write carbon costs into contracts.One clause is added to the European Commissioner's single quotation: Carbon tariff-related costs are adjusted according to changes in EU regulations and certificate prices, and both parties agree on the allocation method. Cost rules are open, and whoever turns them into terms first does not have to bear it alone.
5. Looking back: Two nodes in 2027 and 2028
2027 is the node of "real money": certificates will be sold in February, the first payment will expire on September 30, and the smelting and casting country will be included in quota reference. 2028 is the node of "coverage": the EU has proposed to expand CBAM to about 180 downstream steel and aluminum products, covering fasteners, wires, springs, household metal products, etc. The European Parliament voted with 464 votes on September 15, 2026. The result of the approval adopted the relevant negotiating position-although it will still be negotiated through inter-agency negotiations, the direction has been clear: processing steel coils into products and then exporting cannot avoid carbon costs.
Judgment for steel and aluminum products factories: CBAM will still be a "planning issue" in 2026, a "cash flow issue" in 2027, and an "order qualification issue" in 2028. Prioritize in this order, and classify the data ledger and buyers first in the fourth quarter.
common problems
1. Our factory does not export directly to the EU, but exports through traders. Is CBAM related to us?
related. EU importers need implied emission data of products when clearing the goods, and traders will definitely transmit the data pressure to factories. Building the ledger in advance can instead become a bargaining chip when facing traders-factories with measured data will be more proactive in carbon cost-sharing negotiations.
2. The settlement rate in 2026 is only 2.5%. Can we prepare again in 2027?
Not recommended. Verification requires actual production data for the whole year of 2026. The data is accumulated day by day. If the ledger is replenished at the end of the year, it cannot be replenished. The accounting and verification arrangements for the whole year's data must be completed before the second quarter of 2027, and the preparation work is now just right to start.
3. Small factories have small exports, so will CBAM never be the turn?
The threshold is calculated based on the total annual import volume of EU importers, not your export volume. You may just be one of the suppliers to a major importer, but it still adds up to more than 50 tons. The correct way to do this is to ask buyers one by one, rather than make your own estimates.
--Qihang AI Foreign Trade Research Institute·Let China Intelligent Manufacturing Set sail to the sea| Foreign trade customer consultation: 180-0327-6609
