Sustainability & Carbon Compliance
Sectors currently in scope (cement, steel, aluminium, fertilisers, hydrogen, electricity)
Q1 2026 CBAM certificate price per tonne CO2e
Year free allocation reaches 0%—full certificate liability
Regulation Overview
CBAM is the EU's carbon border pricing mechanism and a cornerstone of the European Green Deal's climate policy architecture. For supply chain teams, the primary obligation is ensuring that embedded greenhouse gas emissions in imported goods are accurately reported, verified, and covered by CBAM certificates priced against the EU Emissions Trading System.
Six sectors are currently in scope: cement, iron and steel, aluminium, fertilisers, hydrogen, and electricity. From January 2026, only Authorised CBAM Declarants may import covered goods. The Commission has proposed expanding the scope to 180 steel- and aluminium-intensive downstream products from 2028—covering car parts, domestic appliances, construction products, and industrial equipment.
CBAM compliance requires installation-level emissions data—direct and, for certain sectors, indirect emissions—from every non-EU producer. As free allocation phases out through 2034, the financial exposure escalates from 2.5% of embedded emissions in 2026 to 100%.
EU importers of cement, iron and steel, aluminium, fertilisers, hydrogen, or electricity
Indirect customs representatives acting as Authorised CBAM Declarants
Non-EU producers supplying emissions data to support EU importer compliance
Non-EU exporters to the EU in covered sectors (data provision obligation)
Companies assembling products from CBAM-covered precursor materials
Downstream manufacturers from 2028 under the proposed scope expansion
Key Thresholds
CBAM requires installation-level emissions data from every non-EU producer—direct emissions by production route, verified by accredited third parties. But suppliers in emerging markets lack carbon accounting infrastructure. Your procurement team sends data requests to 40 steel mills across 8 countries. Three respond with incompatible formats. Twelve use default values that inflate your certificate costs. The rest do not respond at all.
In 2026, the CBAM factor is 2.5%—manageable. By 2030, it reaches 48.5%. By 2034, 100%. A machinery importer bringing in 10,000 tonnes of steel at 1.9 tCO2e/tonne faces costs rising from €35,000 in 2026 to over €1.4 million at full phase-in. Without multi-year emissions visibility across your supply chain, you cannot model cost exposure or make sourcing decisions.
CBAM obligations are triggered by Combined Nomenclature codes listed in Annex I. Misclassification means either non-compliance with reporting obligations or unnecessary certificate purchases. With the proposed 2028 expansion adding 180 downstream CN codes, the classification complexity multiplies—particularly for complex assemblies containing steel or aluminium as functional components.
From 2026, actual emissions data requires verification by an accredited CBAM verifier. But the pool of accredited verifiers is limited, particularly for producers in non-EU jurisdictions. Importers relying on default values face inflated emissions factors based on the highest-emitting countries—turning a data gap into a direct financial penalty on every tonne imported.
Certivo In Action
Certivo in Action — CBAM Workflow
Features Tabs
From Manual Emissions Chasing to Automated Collection
CORA collects and extracts supplier emissions data automatically. Your team focuses on verification exceptions and sourcing decisions—not chasing data across eight countries.
CBAM Declaration Acceleration
Generate complete, audit-ready annual CBAM declarations in hours—not the months of manual compilation across supplier spreadsheets and email chains.
Proactive CBAM Compliance Monitoring
When EU ETS prices shift, scope expands, or benchmarks update, Certivo recalculates your certificate exposure instantly. Model sourcing alternatives before costs escalate through 2034.
Frequently Asked Questions
What products and companies are subject to CBAM obligations?
Any company importing cement, iron and steel, aluminium, fertilisers, hydrogen, or electricity into the EU above the 50-tonne annual de minimis threshold must comply. This includes EU importers, indirect customs representatives, and non-EU producers who must supply installation-level emissions data. From 2028, the proposed scope expansion adds 180 downstream steel and aluminium products, bringing an additional 7,500 importers into CBAM obligations. Certivo's continuous scope monitoring ensures your product portfolio is classified correctly as CBAM evolves.
What are the penalties for CBAM non-compliance?
Penalties mirror the EU ETS excess emissions regime: €100 per tonne of unreported or unsurrendered CO2 equivalent, adjusted annually for inflation. Importers without Authorised Declarant status face border blocks—customs authorities are required to prevent import of CBAM goods by unregistered entities. Persistent non-compliance can result in authorization revocation, supply chain disruption, and public disclosure. CORA's automated declaration workflows and certificate tracking eliminate the data gaps that trigger enforcement action.
How does Certivo handle CBAM's multi-year cost escalation?
Certivo models certificate cost exposure across the full 2026–2034 phase-in schedule, applying the annual CBAM factor (2.5% in 2026, rising to 100% in 2034) against current EU ETS pricing. This gives procurement and finance teams multi-year visibility to evaluate sourcing alternatives, negotiate carbon-adjusted pricing, and budget for escalating certificate obligations—before costs become material.
What emissions data formats does Certivo accept from suppliers?
Certivo accepts any format: PDF declarations, Excel spreadsheets, CBAM communication templates, XML files, verification reports, and freeform responses. CORA extracts installation-level emissions data regardless of format or language, eliminating the need to standardize supplier inputs across jurisdictions. This is critical for CBAM, where non-EU producers across dozens of countries submit data in widely varying formats.
Does Certivo support CBAM alongside related sustainability and substance frameworks?
Yes. Certivo validates supplier data against CBAM, EU CSRD, EU Taxonomy, REACH, RoHS, and PFAS regulations simultaneously—eliminating duplicate data collection campaigns. The same supplier submission that provides embedded emissions for CBAM declarations also feeds Scope 3 reporting for CSRD and substance compliance for REACH, creating a centralized compliance data backbone across frameworks.