CBAM: Carbon Border Adjustment Mechanism Explained

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The European Union’s Carbon Border Adjustment Mechanism (CBAM) is a landmark policy designed to prevent carbon leakage by ensuring that imported goods are subject to the same carbon costs as products manufactured within the EU. By aligning carbon pricing for imports with the EU’s internal carbon market, CBAM aims to promote global emissions reductions and maintain fair competition.​

What Is CBAM?

CBAM is the EU’s tool to put a fair price on the carbon emitted during the production of carbon-intensive goods entering the EU, thereby encouraging cleaner industrial production in non-EU countries. 

The mechanism targets imports from countries outside the EU Emissions Trading System (ETS) to prevent carbon leakage—where businesses relocate production to regions with less stringent environmental regulations, undermining the EU’s climate goals.

How Does CBAM Work?

CBAM operates by requiring importers to purchase certificates that correspond to the carbon price that would have been paid if the goods had been produced under the EU’s carbon pricing rules. The cost of these certificates is based on the price of carbon in the EU ETS.

Importers must submit a CBAM declaration annually, detailing the quantity of goods imported, their embedded emissions, and the number of CBAM certificates surrendered.

Implementation Timeline

  • Transitional Phase (October 1, 2023 – December 31, 2025): Importers are required to report emissions embedded in their goods without financial payments.
  • Full Implementation (Starting January 1, 2026): Importers will need to purchase and surrender CBAM certificates corresponding to the embedded emissions in their imported goods.

Goods Covered by CBAM

Initially, CBAM applies to imports of the following sectors:​

  • Cement
  • Iron and steel
  • Aluminium
  • Fertilisers
  • Electricity
  • Hydrogen​

These sectors are among the most carbon-intensive and are at significant risk of carbon leakage. ​

Implications for Businesses

Companies importing goods into the EU that fall under CBAM’s scope need to:​

  • Monitor Embedded Emissions: Establish systems to calculate and report the carbon emissions associated with their imported goods.​
  • Compliance with Reporting Requirements: Ensure timely and accurate submission of CBAM declarations during the transitional phase.​
  • Financial Planning: Prepare for the financial implications of purchasing CBAM certificates starting in 2026.​

Failure to comply with CBAM requirements can result in penalties and potential disruptions to trade operations.​

Global Reactions and Trade Considerations

CBAM has elicited varied responses globally. Some countries view it as a necessary step towards global climate action, while others, particularly developing nations, express concerns about its impact on their economies and potential conflicts with World Trade Organization (WTO) rules. 

The EU maintains that CBAM is designed to be compatible with WTO obligations and emphasizes its role in encouraging global emissions reductions.

Conclusion

The Carbon Border Adjustment Mechanism represents a significant advancement in the EU’s climate policy, aiming to level the playing field for EU producers and drive global emissions reductions. Businesses involved in importing covered goods into the EU must proactively adapt to CBAM’s requirements to ensure compliance and maintain competitiveness in the evolving regulatory landscape.​

 

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