CBAM: Implementation of the definitive phase – BusinessEurope fact check

Introduction

The Carbon Border Adjustment Mechanism (CBAM) entered into application on 1 October 2023 with a transitional phase, before the start of its definitive phase in January 2026. While the definitive regime introduced new compliance obligations, the sales of CBAM certificates will begin in February 2027 allowing an initial implementation period for companies to adapt to the new system. The first annual CBAM declaration and the corresponding surrender of certificates for goods imported in 2026 will be due by 30 September 2027.

BusinessEurope has consistently supported the objective of CBAM while stressing that its implementation should remain proportionate, workable for companies and minimise unnecessary administrative burden. CBAM is an essential complement to the EU Emissions Trading System (EU ETS), addressing risks of carbon leakage and circumvention, while safeguarding the environmental integrity and competitiveness objectives of the EU’s climate policy framework.

With CBAM now in its definitive phase, this fact check aims to identify the main challenges faced by European companies during the first months of full implementation. The objective is to gather concrete feedback from members on the practical difficulties encounter and to identify possible adjustments to the functioning of the system.