What is the main focus of the EU-CBAM transitional phase?

The EU-CBAM transitional phase primarily focuses on emissions reporting.

What changes will occur during the definitive phase starting in 2026?

The definitive phase will introduce higher requirements such as emissions monitoring, reporting, and verification, with obligations for reliable emissions data verified by an accredited body.

What are the reporting obligations during the transitional phase from 2023 to 2025?

Obligations include reporting direct and indirect emissions associated with exported products, using EU-recognized calculation methodologies, and ensuring data traceability and quality.

What is the financial requirement for imported goods from 2026 onwards under EU-CBAM?

Importers will need to purchase CBAM certificates corresponding to embedded emissions, with higher financial impact for products with a high carbon footprint.

EU Carbon Border Adjustment Mechanism (EU-CBAM): What companies need to know as 2026 approaches

Q: Which sectors will be affected by EU-CBAM obligations?

Sectors affected include steel, aluminum, cement, fertilizers, and electricity, with the scope expected to expand over time.

The EU Carbon Border Adjustment Mechanism (EU-CBAM) is a key instrument of the European Union aimed at preventing carbon leakage and ensuring fair competition between EU manufacturers and importers from third countries. By aligning the carbon costs of imported goods with those produced within the EU, the mechanism supports the EU’s climate objectives while encouraging cleaner production globally.

As EU-CBAM moves closer to its definitive phase starting on 1 January 2026, the regulatory landscape for affected companies is becoming increasingly concrete.

From transitional phase to definitive phase

Since the start of the transitional phase, EU-CBAM has primarily focused on emissions reporting. However, the definitive phase will introduce significantly higher requirements, particularly in the areas of emissions monitoring, reporting, and verification.

Companies importing EU-CBAM-covered goods into the EU will be required to provide reliable emissions data across their supply chains and ensure that this data is verified by an accredited verification body. These obligations will apply to several energy-intensive sectors, including steel, aluminum, cement, fertilizers, and electricity, with the scope expected to expand over time.

Key Obligations

During the transitional phase (2023–2025):

Report direct and indirect emissions associated with exported products
Use EU-recognized calculation methodologies
Ensure data traceability and quality

From 2026 onwards:

Purchase CBAM certificates corresponding to embedded emissions
Higher financial impact for products with a high carbon footprint

A strong global climate signal

EU-CBAM goes beyond EU borders. By extending European climate protection standards to imported goods, the mechanism sends a clear signal to global markets and creates incentives for more climate-friendly production worldwide.

At the same time, the regulation presents practical challenges. Accurate emissions data must often be obtained from producers in third countries, requiring new data flows, methodologies, and governance structures within companies.

Accreditation developments and verification readiness

The European Commission has recently published a delegated act on accreditation requirements for EU-CBAM verifiers. This act enables verification bodies already accredited for relevant activity groups under the EU Emissions Trading System (EU ETS – ETS 1) to apply for an extension of their accreditation scope to include EU-CBAM activities.

Kiwa, which is active in several European countries as an accredited EU ETS verification body and is expanding its portfolio toward ETS 2, is closely monitoring these regulatory developments. Based on its extensive experience in emissions verification and climate reporting, Kiwa is preparing to support future EU-CBAM verification activities as the framework continues to evolve.

CBAM Requirements

CBAM requires:

Robust carbon footrpint data
A life cycle assessment (LCA) approach
Strong measurement, reporting and verification (MRV) systems

A well-structured Corporate Carbon Footprint (CCF) and verified EPDs significantly facilitate compliance and reduce regulatory and financial risks.

Several delegated and implementing acts are currently being published at EU level, covering topics such as verification principles, methodologies for the definitive phase, and the calculation of CO₂ prices in third countries. As a result, regulatory clarity is increasing—but so are expectations for compliance.

Companies that begin preparing early can reduce compliance risks, improve data quality, and gain greater certainty ahead of the definitive phase.

Learn more

If you would like to stay informed about EU-CBAM developments or understand what upcoming verification requirements may mean for your organization, Kiwa experts are available to share insights and practical guidance as the regulatory framework continues to take shape.

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