What Happened: CBAM Enters Its Definitive Regime
Since 1 January 2026, CBAM, the EU's carbon border adjustment mechanism, has been operating in its full, definitive regime. The transitional period that ran from October 2023 to 31 December 2025 is over: quarterly reports with no payments are history, replaced by an annual declaration and real financial obligations under Regulation (EU) 2023/956.
For Ukrainian producers of steel, aluminium, fertilisers and cement, this isn't another piece of European news with a delayed effect. Emissions from 2026 are accumulating right now, and EU buyers will pay real money for them for the first time. The emissions questionnaires that felt like a bureaucratic warm-up during the transitional period now directly affect the price of every tonne in the contract.
As of September 2026, the mechanism has been running in its new mode for eight months, and the practice is taking shape: importers are registering as authorised CBAM declarants, collecting data from suppliers and calculating future certificate costs. We covered who falls under the mechanism and how to calculate embedded emissions in our CBAM reporting guide for exporters. This piece is about what exactly the definitive regime changed and which dates now set the exporter's calendar.
The Definitive Regime in Numbers
From 1 January 2026, importers of goods from the cement, iron and steel, aluminium, fertiliser, electricity and hydrogen sectors declare embedded emissions and surrender certificates. Imports below 50 tonnes per year are exempt. The first declaration is due by 30 September 2027 for 2026 imports. The certificate price is tied to the auction price of EU ETS allowances.
CBAM Certificates: How the Financial Obligations Work
The core of the new regime is certificates. An importer with authorised CBAM declarant status declares the embedded emissions of imported goods each year and surrenders the corresponding number of certificates. They buy them from the national authority in their country of establishment, and the price, under the European Commission's rules, is calculated from the auction price of EU ETS allowances in euros per tonne of CO₂: a quarterly average applies through 2026, a weekly average from 2027.
There's also a safeguard against double payment. If a carbon price has already been paid in the country of production, the importer can deduct the corresponding amount from their obligations.
| Date | What happens |
|---|---|
| 31 December 2025 | The transitional period ends: quarterly reports, no payments |
| 1 January 2026 | The definitive regime starts: annual declaration and CBAM certificates |
| Through 2026 | Certificate price equals the quarterly average EU ETS auction price |
| From 2027 | Certificate price equals the weekly average EU ETS auction price |
| 30 September 2027 | First declaration and certificate surrender for 2026 imports |
The calendar here is deceptive. The first financial settlement won't happen until autumn 2027, which creates a sense of spare time. In reality there is none: the declaration for 2026 will be built from data the producer is either collecting now or won't have at all. You can't reconstruct emissions retroactively; meters don't rewind.
The 50-Tonne Threshold: Who the Definitive Regime Won't Touch
Alongside the switch to the full regime, a simplification adopted by Regulation (EU) 2025/2083 in October 2025 kicked in. If an importer brings less than 50 tonnes of CBAM goods per year into the EU in total, the mechanism's obligations don't apply to them. The threshold is counted by net mass, combined across four sectors: iron and steel, aluminium, fertilisers and cement. It doesn't apply to electricity or hydrogen.
The scale of the simplification is considerable: by the European Commission's estimate, the exemption took roughly 182,000 importers out of the mechanism, mostly small businesses, while more than 99% of in-scope emissions stayed covered.
It's easy to draw the wrong conclusion here. The threshold is counted on the buyer's side, by their total annual imports, not by your individual contract. A 20-tonne shipment of profiles doesn't exempt an importer who picks up another 40 tonnes elsewhere. So the line "we're small, this doesn't concern us" only works after checking with your specific buyer.
What Importers Now Demand from Ukrainian Suppliers
Legally, all obligations under the mechanism sit with the importer. The source of the data, though, is a single one: the producer. Their obligation, your numbers.
For the declaration, an authorised CBAM declarant has two routes: actual installation data from the supplier, or default values published by the Commission for the definitive period. The topic turned out to be so alive that in June 2026 the European Commission issued a dedicated factsheet on choosing between actual data and default values in the declaration.
A typical request from a European buyer in 2026 includes:
- the name and location of the installation where the goods were produced;
- direct emissions per tonne of product;
- indirect emissions from the electricity consumed in production;
- the methodology: how exactly each number was calculated.
In practice, one more item keeps joining that list: whether the company runs an environmental management system. The buyer wants to understand how much the numbers can be trusted and whether the supplier will reproduce the same result next year.
Supplier Silence Means Default Values
If the producer doesn't provide data, the importer declares the goods using the Commission's averaged values. The shipment won't stop, but the carbon cost of your products will be set by someone else's table, not your own accounting. That's a weak position in the next contract's price talks: a competitor with verified numbers of their own holds an argument you don't.
Your Emissions Data Must Survive the Importer's Checks
Ekontrol helps manufacturers set up emissions accounting and an environmental management system that meet CBAM demands. A Bureau Veritas partner in Ukraine: diagnostics, implementation, audit preparation.
ISO 14001 Certification with EkontrolWhat's Next: The EU Council Agreed to Extend CBAM
The definitive regime isn't the mechanism's final shape. On 12 June 2026, the EU Council agreed to strengthen CBAM: extending it to specific downstream goods and reinforcing the safeguards against circumvention. The European Commission welcomed the decision.
One clarification is needed here: this is the Council's agreed position, not a regulation in force. There's no final text and no list of new commodity codes yet. The direction is clear, though: the mechanism's scope will keep growing, and a producer whose goods formally sit outside it today may find themselves inside within a year or two. Checking your products' CN codes against Annex I of the regulation is now a yearly exercise, not a one-off.
The Business Consequence: Emissions Data Is Now Part of the Price
The main thing the definitive regime did was turn emissions data from reference information into a financial variable. The supplier's numbers now determine how many certificates the buyer purchases and what the carbon component in the product's price will be. A one-off Excel table can't carry that role: the numbers have to be reproducible, comparable year to year and ready for a verifier's follow-up questions.
You need a system that produces this data. That's why buyers' requests increasingly come in pairs: emissions data plus questions about environmental management. ISO 14001 certification isn't a requirement of the regulation, but it closes the weakest spot of this data: trust in the process that created it. We covered how such a system is built from zero to certificate in our complete ISO 14001 guide.
The place to start is simple: an inventory of installations, emission sources and the places where primary data lives. If you need an outside view, a pre-certification readiness assessment will show the gaps between your current accounting and what the importer will ask for. And if a buyer has already set a data deadline, contact the Ekontrol team and we'll sort the situation out before it becomes a contract problem.
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Free ConsultationOn This Page
- What Happened: CBAM Enters Its Definitive Regime
- CBAM Certificates: How the Financial Obligations Work
- The 50-Tonne Threshold: Who the Definitive Regime Won't Touch
- What Importers Now Demand from Ukrainian Suppliers
- What's Next: The EU Council Agreed to Extend CBAM
- The Business Consequence: Emissions Data Is Now Part of the Price
- FAQ: The CBAM Definitive Regime in Questions and Answers
What Happened: CBAM Enters Its Definitive Regime
Since 1 January 2026, CBAM, the EU's carbon border adjustment mechanism, has been operating in its full, definitive regime. The transitional period that ran from October 2023 to 31 December 2025 is over: quarterly reports with no payments are history, replaced by an annual declaration and real financial obligations under Regulation (EU) 2023/956.
For Ukrainian producers of steel, aluminium, fertilisers and cement, this isn't another piece of European news with a delayed effect. Emissions from 2026 are accumulating right now, and EU buyers will pay real money for them for the first time. The emissions questionnaires that felt like a bureaucratic warm-up during the transitional period now directly affect the price of every tonne in the contract.
As of September 2026, the mechanism has been running in its new mode for eight months, and the practice is taking shape: importers are registering as authorised CBAM declarants, collecting data from suppliers and calculating future certificate costs. We covered who falls under the mechanism and how to calculate embedded emissions in our CBAM reporting guide for exporters. This piece is about what exactly the definitive regime changed and which dates now set the exporter's calendar.
The Definitive Regime in Numbers
From 1 January 2026, importers of goods from the cement, iron and steel, aluminium, fertiliser, electricity and hydrogen sectors declare embedded emissions and surrender certificates. Imports below 50 tonnes per year are exempt. The first declaration is due by 30 September 2027 for 2026 imports. The certificate price is tied to the auction price of EU ETS allowances.
CBAM Certificates: How the Financial Obligations Work
The core of the new regime is certificates. An importer with authorised CBAM declarant status declares the embedded emissions of imported goods each year and surrenders the corresponding number of certificates. They buy them from the national authority in their country of establishment, and the price, under the European Commission's rules, is calculated from the auction price of EU ETS allowances in euros per tonne of CO₂: a quarterly average applies through 2026, a weekly average from 2027.
There's also a safeguard against double payment. If a carbon price has already been paid in the country of production, the importer can deduct the corresponding amount from their obligations.
| Date | What happens |
|---|---|
| 31 December 2025 | The transitional period ends: quarterly reports, no payments |
| 1 January 2026 | The definitive regime starts: annual declaration and CBAM certificates |
| Through 2026 | Certificate price equals the quarterly average EU ETS auction price |
| From 2027 | Certificate price equals the weekly average EU ETS auction price |
| 30 September 2027 | First declaration and certificate surrender for 2026 imports |
The calendar here is deceptive. The first financial settlement won't happen until autumn 2027, which creates a sense of spare time. In reality there is none: the declaration for 2026 will be built from data the producer is either collecting now or won't have at all. You can't reconstruct emissions retroactively; meters don't rewind.
The 50-Tonne Threshold: Who the Definitive Regime Won't Touch
Alongside the switch to the full regime, a simplification adopted by Regulation (EU) 2025/2083 in October 2025 kicked in. If an importer brings less than 50 tonnes of CBAM goods per year into the EU in total, the mechanism's obligations don't apply to them. The threshold is counted by net mass, combined across four sectors: iron and steel, aluminium, fertilisers and cement. It doesn't apply to electricity or hydrogen.
The scale of the simplification is considerable: by the European Commission's estimate, the exemption took roughly 182,000 importers out of the mechanism, mostly small businesses, while more than 99% of in-scope emissions stayed covered.
It's easy to draw the wrong conclusion here. The threshold is counted on the buyer's side, by their total annual imports, not by your individual contract. A 20-tonne shipment of profiles doesn't exempt an importer who picks up another 40 tonnes elsewhere. So the line "we're small, this doesn't concern us" only works after checking with your specific buyer.
What Importers Now Demand from Ukrainian Suppliers
Legally, all obligations under the mechanism sit with the importer. The source of the data, though, is a single one: the producer. Their obligation, your numbers.
For the declaration, an authorised CBAM declarant has two routes: actual installation data from the supplier, or default values published by the Commission for the definitive period. The topic turned out to be so alive that in June 2026 the European Commission issued a dedicated factsheet on choosing between actual data and default values in the declaration.
A typical request from a European buyer in 2026 includes:
- the name and location of the installation where the goods were produced;
- direct emissions per tonne of product;
- indirect emissions from the electricity consumed in production;
- the methodology: how exactly each number was calculated.
In practice, one more item keeps joining that list: whether the company runs an environmental management system. The buyer wants to understand how much the numbers can be trusted and whether the supplier will reproduce the same result next year.
Supplier Silence Means Default Values
If the producer doesn't provide data, the importer declares the goods using the Commission's averaged values. The shipment won't stop, but the carbon cost of your products will be set by someone else's table, not your own accounting. That's a weak position in the next contract's price talks: a competitor with verified numbers of their own holds an argument you don't.
Your Emissions Data Must Survive the Importer's Checks
Ekontrol helps manufacturers set up emissions accounting and an environmental management system that meet CBAM demands. A Bureau Veritas partner in Ukraine: diagnostics, implementation, audit preparation.
ISO 14001 Certification with EkontrolWhat's Next: The EU Council Agreed to Extend CBAM
The definitive regime isn't the mechanism's final shape. On 12 June 2026, the EU Council agreed to strengthen CBAM: extending it to specific downstream goods and reinforcing the safeguards against circumvention. The European Commission welcomed the decision.
One clarification is needed here: this is the Council's agreed position, not a regulation in force. There's no final text and no list of new commodity codes yet. The direction is clear, though: the mechanism's scope will keep growing, and a producer whose goods formally sit outside it today may find themselves inside within a year or two. Checking your products' CN codes against Annex I of the regulation is now a yearly exercise, not a one-off.
The Business Consequence: Emissions Data Is Now Part of the Price
The main thing the definitive regime did was turn emissions data from reference information into a financial variable. The supplier's numbers now determine how many certificates the buyer purchases and what the carbon component in the product's price will be. A one-off Excel table can't carry that role: the numbers have to be reproducible, comparable year to year and ready for a verifier's follow-up questions.
You need a system that produces this data. That's why buyers' requests increasingly come in pairs: emissions data plus questions about environmental management. ISO 14001 certification isn't a requirement of the regulation, but it closes the weakest spot of this data: trust in the process that created it. We covered how such a system is built from zero to certificate in our complete ISO 14001 guide.
The place to start is simple: an inventory of installations, emission sources and the places where primary data lives. If you need an outside view, a pre-certification readiness assessment will show the gaps between your current accounting and what the importer will ask for. And if a buyer has already set a data deadline, contact the Ekontrol team and we'll sort the situation out before it becomes a contract problem.
