CBAM Transition: Reporting and Financial Obligations 

December 17, 2025

Overview 

Effective Date: January 1, 2026  
Summary: The European Union’s Carbon Border Adjustment Mechanism (CBAM) will shift from quarterly reporting to annual monitoring of embedded greenhouse gas (GHG) emissions for imports. The transition to the definitive CBAM regime will change reporting obligations for importers and introduce new financial responsibilities.  
Upcoming Changes:  

• Starting January 1, 2026, quarterly reporting will shift to annual monitoring of embedded GHG emissions. 
• CBAM declarants must purchase and surrender CBAM certificates for emissions from imports. 
• The European Commission's "Omnibus I" package will modify financial obligations, allowing certificate purchases from February 2027. 
• Existing rules for electricity imports from Contracting Parties remain largely unchanged. 

Covered Sectors:  

• Cement 
• Iron & Steel 
• Aluminum 
• Fertilizers 
• Electricity 
• Hydrogen 

Key Dates and Scope: 

Purpose and Rationale for the CBAM Shift 

Switching CBAM from quarterly to annual monitoring strengthens its role as a climate policy tool, enforcing carbon pricing on imports to prevent carbon leakage and support EU goals under the Fit for 55 agenda and the Green Deal. This change also simplifies compliance for businesses. 

Protecting EU Climate Policy and Ensuring Fair Competition 

The transition to CBAM aims to protect the EU’s climate policy and maintain fair competition. As emissions rules tighten and free allowances under the EU Emissions Trading System are phased out, CBAM ensures imports face similar carbon costs as EU-made goods. 

Preventing Carbon Leakage and Encouraging Cleaner Production 

CBAM aligns carbon costs for imports and domestic goods to prevent carbon leakage and discourage companies from moving production to countries with weaker environmental standards. It also motivates non-EU producers to lower emissions to stay competitive in the EU market. 

Trade Implications  

1. Increased Costs for Non-EU Exporters

Non-EU exporters will face higher costs when selling covered goods in the EU because they must purchase CBAM certificates for each shipment. These added expenses can reduce profit margins and weaken price competitiveness compared to EU-based producers. 

2. Shifting Supply Chains and Trade Patterns 

CBAM-related costs may push exporters and supply chain managers to rethink sourcing and distribution strategies. Trade is likely to shift toward EU producers or countries with similar carbon pricing systems, such as Iceland, Norway, and Switzerland, where CBAM costs do not apply. 

3. Challenges for EU Downstream Industries 

EU industries that depend on CBAM-regulated inputs may see higher production costs, which can reduce their competitiveness. Without additional protective measures, these increased input costs may translate into higher prices for finished goods in both EU and global markets.

4. Mitigating Carbon Leakage  

CBAM aims to prevent companies from relocating production to countries with weaker emissions regulations. By aligning carbon costs for EU and non-EU producers, the mechanism helps maintain fair competition under the EU Emissions Trading System. 

5. Potential for Broader Scope in the Future  

CBAM may expand to cover more products, such as crude petroleum, chemicals, and downstream goods like automobiles. Such an expansion would broaden its impact and further influence global trade patterns and industrial competitiveness. 

Conclusion 

CBAM is a strategic shift to enhance climate action and protect EU competitiveness. Applying carbon pricing to imports promotes fair competition and global decarbonization. While it poses challenges for non-EU exporters and downstream industries, CBAM signals a move toward sustainable trade. Businesses that adapt early will be better equipped for a carbon-conscious market. 

Crane Worldwide combines regulatory expertise, technology, and global logistics capabilities to help businesses stay compliant, avoid penalties, and maintain competitiveness in a carbon-conscious market. Contact us today.