Supplier emissions data: the biggest “make-or-break” cost driver
CBAM requires installation-level (site-specific), verified emissions data. In practice, this means suppliers need to provide actual verified emissions (direct and indirect where applicable) calculated under CBAM rules.
If suppliers cannot provide compliant data, you may be pushed onto default values, which are often conservative and can inflate CBAM costs. Supplier readiness also becomes a supply continuity risk: where key suppliers cannot provide compliant data, importers may need to switch sourcing, renegotiate terms, or build data obligations into purchasing contracts.
Key policy signals (June–July 2026): likely expansion and tighter controls
Recent EU signals from the Council of the EU and the European Parliament’s Environment Committee (ENVI) supported proposals that would:
- Extend CBAM to additional downstream goods (more finished/semi-finished products), reportedly 400+ additional product codes. This could expose businesses importing finished goods, even if they do not import primary materials today.
- Strengthen anti-avoidance rules to discourage rerouting or minimal processing designed to avoid CBAM
- Remove the proposed “emergency brake” mechanism (previously discussed in relation to fertilisers), signalling a regime that is more consistent but less flexible during periods of market disruption
Status: these changes are not final EU law. Next steps include a European Parliament plenary vote expected mid September 2026, followed by trilogue negotiations (Parliament–Council–Commission), where details (including the final list of codes) may still change.
17 July 2026: Commission proposal that may ease future cost pressure
On 17 July 2026, the European Commission published a proposal that—if adopted—could reduce longer-term CBAM cost pressure and smooth the transition. Key elements include:
- A slower ramp-up from 2028, by lowering phase-in percentages (so cost impacts may increase more gradually)
- A proposal to delay the full phase-in date from 2034 to 2038, potentially giving businesses more time to adapt
- Exploration of EU-level use of international carbon credits to help ease pressure on EU carbon prices (importers would not buy or use these credits directly, but it could help stabilise the underlying price environment)
- A more tailored phase-in for any new goods added to CBAM, which could reduce “cliff edge” impacts if your product range expands into newly covered categories
Practical takeaway: this is encouraging, but it remains a proposal rather than law. We recommend continuing to plan against the current rules and timelines, treating any relief as potential upside until formally confirmed.
CBAM certificate price update (published)
The European Commission has published CBAM certificate prices:
- Q1 2026: €75.36 per tonne of CO₂e
- Q2 2026: €75.28 per tonne of CO₂e
Expected next publications:
- Q3 2026 price: around 5 October 2026
- Q4 2026 price: around 4 January 2027
Importers will begin purchasing CBAM certificates from February 2027 to cover 2026 embedded emissions.
What you can do now
Even before the rules are final, sensible steps include:
- Assess potential exposure to downstream goods, especially products with significant steel/aluminium content
- Request verified emissions data now and build it into supplier contracts
How we can support you
If helpful, we can support you with:
- Confirming whether your products are in scope (including CN code mapping)
- Estimating your potential CBAM cost exposure using default emissions
- Supply chain analysis
If you’d like to discuss what these developments could mean for your imports, reporting, and financial exposure, please let us know.
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