CBAM is not legally defined as a tax. It is a carbon pricing mechanism that requires importers to purchase CBAM certificates corresponding to the embedded emissions of goods imported into the EU, in accordance with the CBAM Regulation.
As CBAM enters its definitive phase, operators and importers face new obligations for emissions data reporting, financial exposure management and future verification requirements across CBAM-affected supply chains.
We provide independent CBAM pre-verification and support services across all affected sectors – including iron and steel, cement, aluminum, fertilizers, hydrogen and electricity – helping operators and importers involved in CBAM-affected supply chains to manage exposure and prepare for accredited verification.
Discover the benefits of our CBAM services
- Understand CBAMLearn how the Carbon Border Adjustment Mechanism works, including the key timelines and the sectors affected.
- Gain CBAM pre-verificationGet independent assessment of the monitoring systems operators used to monitor and report embedded emissions for each product.
- Reduce CBAM exposureUnderstand the financial impact of default values and how pre-verification can help manage risk.
The CBAM timeline
- 2023–2025Transitional reporting period
- January 1, 2026The definitive CBAM regime begins. Financial obligations apply and companies seeking to reduce CBAM exposure through actual emissions data should begin preparing for future accredited verification requirements. Pre-verification is becoming increasingly important to assess an operator’s readiness to successfully undergo accredited verification in future.
- February 1, 2027CBAM certificates become available for purchase, covering embedded emissions linked to 2026 imports.
- September 30, 2027First annual CBAM declaration and CBAM certificate surrender deadline for imports made during 2026.
Why SGS?
As the world's leading testing, inspection and certification company, we bring proven expertise in greenhouse gas and EU ETS verification to every Carbon Border Adjustment Mechanism engagement. Our independent, third-party track record is delivered through a global network of qualified technical experts operating locally across CBAM-affected markets. We apply extensive experience of EU climate regulations in real operational contexts, with delivery models designed to support compliance and scale as CBAM obligations evolve.
FAQs
Under the definitive CBAM regime, importers must submit annual CBAM declarations covering the embedded emissions of imported goods. From 2027, importers will be required to purchase and surrender CBAM certificates corresponding to the emissions associated with goods imported during 2026. The number of certificates required reflects the difference between the carbon price paid by an operator producing the goods outside the EU and the carbon price that would have been paid had those goods been produced under the EU Emissions Trading System (EU ETS).
CBAM moved through a transitional reporting period between 2023 and 2025, and entered its definitive regime on January 1, 2026, when financial obligations apply. Companies seeking to reduce CBAM exposure through actual emissions data should begin preparing for future accredited verification requirements, and pre-verification is becoming an increasingly important step in assessing readiness.
Key milestones include:
- January 1, 2026: the definitive CBAM regime began and financial obligations apply
- February 1, 2027: CBAM certificates become available for purchase, covering embedded emissions linked to 2026 imports
- September 30, 2027: the first annual CBAM declaration and certificate surrender deadline falls due for 2026 imports
Currently, CBAM applies primarily to selected goods in the iron and steel, aluminum, cement, fertilizer, hydrogen and electricity sectors. The scope is evolving, however: the European Commission proposal published on December 17, 2025, amending Regulation (EU) 2023/956, includes an extension to additional carbon-intensive downstream steel and aluminum products.
While CBAM does not yet apply to all finished goods, its scope is expected to expand over time to include more processed and semi-finished products.
CBAM covers CO₂ and, for certain sectors, also N₂O (fertilizers) and PFCs (aluminum). Depending on the product category, both direct emissions and, in some cases, indirect emissions from electricity consumption must be reported. Emissions are calculated and reported using sector-specific methodologies and functional units defined under the CBAM regulation, to ensure consistency and comparability across operators.
We support organizations with CBAM readiness through independent pre-verification services. Our CBAM pre-verification services help operators and importers assess the credibility of emissions data, strengthen readiness for future accredited verification and reduce exposure to unnecessary CBAM costs.
