CBAM: the new landscape for European importers

The CBAM is much more than just a new customs procedure. It is a tool set to have a profound impact on the way businesses manage imports, select suppliers and demonstrate their environmental sustainability. Preparing for it now means not only avoiding future challenges, but also transforming compliance obligations into an asset for the entire organisation. In an economic landscape increasingly focused on sustainability, the ability to adapt quickly to new European rules could make the difference between being forced to adapt to change and using it as a driver for growth.

With the Carbon Border Adjustment Mechanism (CBAM), the European Union is introducing one of the most ambitious tools in its climate policy. Following a transitional phase focused primarily on data collection and familiarisation with the new system, businesses now face the most tangible challenge: transforming regulatory obligations into effective operational processes. For many companies importing goods from non-European countries, the CBAM represents a significant change affecting not only customs procedures but also supply chain management, environmental data collection and corporate compliance.

CBAM: From theory to practice

The primary objective of the Carbon Border Adjustment Mechanism (CBAM) is to address the phenomenon known as “Carbon Leakage” —the relocation of production activities to countries with less stringent environmental regulations than those in the EU. Without corrective measures, European manufacturers subject to the costs of the EU Emissions Trading System (ETS) could face a significant competitive disadvantage compared to producers operating with lower carbon-related costs. Through the introduction of CBAM, the European Union aims to establish a level playing field by assigning a carbon cost to certain imported goods based on greenhouse gas emissions generated during their production. Scope is the support of both EU’s climate objectives and fair competition in global trade. Unfortunately, the transitional phase has demonstrated that collecting the required emissions data is far from straightforward. Many companies have encountered challenges in obtaining reliable information from suppliers located outside the EU, particularly when dealing with complex supply chains or multiple stakeholders across different regions. The quality and availability of emissions data have emerged as critical issues. In many cases, suppliers lacked the systems and methodologies needed to accurately measure and document the information required under European legislation. As a result, companies have faced delays, reporting uncertainties and additional administrative burdens.

To support businesses during this transition, the European Commission has gradually released guidelines, technical documents and operational clarifications. Nevertheless, responsibility for the accuracy and completeness of CBAM declarations ultimately remains with the importer.

New responsibilities for Businesses and the importance of Contractual Safeguards

As the full implementation of CBAM draws closer, companies must prepare for a more demanding compliance environment. Affected businesses will need to establish robust procedures for registration, monitoring, reporting and documentation. Particular attention must be paid to collecting accurate information on the embedded emissions of imported goods, preparing annual CBAM declarations and managing CBAM certificates, whose value will be linked to developments in the EU carbon market. Compliance will therefore extend well beyond a simple administrative exercise, requiring close cooperation between procurement, logistics, customs, sustainability and finance teams. One aspect that is often overlooked is the contractual impact of CBAM. Since importers will increasingly rely on emissions data provided by foreign manufacturers, the quality and reliability of that information become essential for regulatory compliance. For this reason, companies should review existing supply agreements and consider introducing specific provisions covering emissions reporting obligations, data-sharing requirements, liability for inaccurate information and audit rights where necessary. A proactive contractual approach can significantly reduce compliance risks, improve transparency and strengthen legal certainty throughout the supply chain.

Turning a regulatory challenge into a strategic opportunity

Although CBAM is frequently viewed as an additional regulatory burden, forward-looking companies are increasingly recognising it as a strategic opportunity. The ability to monitor emissions across the supply chain, enhance transparency and engage more closely with suppliers can create meaningful competitive advantages. Businesses that invest early in data quality, digitalised processes and employee training will be better positioned to navigate future regulatory developments and respond to growing market expectations around sustainability.

CBAM is more than a compliance requirement. It represents a shift towards greater accountability and transparency in international trade. Companies that embrace this change proactively will not only reduce regulatory risk but also strengthen their long-term competitiveness in an increasingly sustainability-driven global economy.