CBAM's Definitive Phase: What Importers Need Before January

From January 1, the Carbon Border Adjustment Mechanism moves from transitional reporting into its definitive phase. Importers of covered goods — steel, aluminium, cement, fertilisers, hydrogen and electricity — must hold authorised declarant status.

The practical bottleneck is supplier data. Embedded-emissions values need to come from installation operators, and default values will carry a growing penalty over time.

Our recommendation: segment suppliers by CBAM exposure now, issue data requests this quarter, and model certificate cost into 2027 landed-cost assumptions.