CBAM regulations explained: what businesses need to know about EU and UK requirements, reporting, and trade impact

The Carbon Border Adjustment Mechanism (CBAM) is one of the most consequential trade and climate regulations to emerge this decade, impacting global trade and sustainability. For large businesses operating across international supply chains, it introduces new requirements around carbon reporting, cost exposure, and compliance.

In short, CBAM ensures that imported goods are subject to the same carbon costs as those produced domestically, reducing the risk of “carbon leakage” and creating a more level playing field.

But beyond its environmental intent, CBAM is fundamentally a data and supply chain challenge. Businesses without clear visibility across their operations face increasing risk as reporting requirements tighten and financial implications scale.

What is CBAM?

CBAM definition

CBAM stands for Carbon Border Adjustment Mechanism, a policy introduced by the European Union to apply a carbon price to imported goods based on their embedded emissions.

In practice, this means importers must account for the carbon cost embedded in goods arriving from outside the EU. It applies primarily to six carbon-intensive sectors: steel, aluminium, cement, fertilisers, hydrogen, and electricity.

How CBAM works

Starting with 2026, EU importers are required to pay a carbon adjustment based on embedded emissions, aligning imported goods with domestic carbon pricing systems.

While the scope may appear narrow, it is strategically significant. CBAM-covered trade flows cover a reported 3% of EU imports from non-EU countries, while the sectors in scope account for 7.0% of manufacturing production and 2.3% of total output in the EU (OECD, 2025).

Why CBAM matters for businesses

This highlights an important point for businesses. CBAM is not designed to cover everything, but it targets the most carbon-intensive and economically sensitive parts of the supply chain, where impact is greatest.

CBAM is closely linked to broader sustainability and compliance frameworks, including extended producer responsibility, which are collectively increasing transparency across product lifecycles.

What is the purpose of the EU and UK CBAM regulations?

The primary goal of CBAM is to reduce carbon leakage and support decarbonisation. But its role is broader than that.

1. Creating a level playing field

Without CBAM, companies operating in regions with strict carbon regulations will incur higher costs than those importing goods from less regulated markets. CBAM aims to correct this imbalance by aligning carbon costs globally.

2. Driving global emissions reduction

By attaching a financial cost to carbon, CBAM incentivises suppliers worldwide to reduce emissions. This shifts sustainability from a voluntary initiative to a commercial necessity.

3. Increasing transparency across supply chains

CBAM requires businesses to understand emissions at a much deeper level. This aligns with wider trends towards lifecycle accountability, when organisations must track environmental impact across the full value chain.

4. Supporting systemic change

The Circularity Gap Report 2026 highlights that more than half of global greenhouse gas emissions come from material extraction and processing, reinforcing the need for systemic interventions like CBAM.

This is not just about emissions. It is about redesigning how value is created and retained across the economy.

How CBAM will impact international trade and carbon emissions

CBAM will reshape global trade in several important ways.

Shifting supply chain dynamics

CBAM is already significant in scale and will reshape international trade dynamics.

Based on OECD analysis, the mechanism would have applied to approximately USD 132 billion worth of trade, representing 0.37% of global trade (OECD, 2025).

For large organisations, this is a clear signal that this has direct commercial implications for sourcing, pricing, and supplier strategy. Businesses will increasingly prioritise lower-carbon suppliers to reduce both cost exposure and compliance risk.

Introducing new cost pressures

CBAM effectively introduces a new cost layer based on carbon intensity. For high-emission products, this could significantly increase import costs, particularly for businesses with limited visibility on emissions.

Driving emissions reduction

From an emissions perspective, CBAM is designed to deliver a measurable impact.

It is estimated to cover 171 million tonnes of CO₂ equivalent, accounting for around 0.31% of global emissions.

More importantly, the mechanism is effective. With CBAM in place, global emissions are expected to fall by 0.54%, with around one-third of that reduction directly attributable to the policy itself (OECD, 2025).

This demonstrates that CBAM is not just a compliance requirement. It is a policy tool that actively drives emissions reduction by influencing how and where goods are produced.

This aligns with findings from the Circularity Gap Report 2026, which highlights that inefficient resource use and linear systems are a major driver of emissions and value loss.

The report estimates that €25.4 trillion in economic value is lost annually due to inefficient material use, equivalent to around 31% of global GDP.

Reducing emissions and improving efficiency are therefore closely linked.

EU vs UK CBAM, key differences

While both the EU and UK are implementing CBAM frameworks, there are important differences businesses must understand.

For large organisations, this means compliance cannot be managed as a single process. Businesses will need flexible systems capable of handling multiple regulatory frameworks simultaneously.

EU CBAM

The current EU CBAM status is:

• In the definitive regime since 1 January 2026
• Only authorised CBAM declarants may import CBAM goods above the threshold
• Financial obligations phase in during 2027 (certificate sales from 1 February 2027l first declaration and surrender by 30 September 2027)
• Covers six sectors; linked to the EU ETS

Get EU CBAM support

UK CBAM

The UK government has confirmed that it will introduce its own CBAM from 1^st January 2027, legislated within the Finance Act 2026.

The UK approach is closely aligned in principle but differs in key areas:

• Applies to imports of aluminium, cement, fertilisers, hydrogen, and iron and steel
• Designed to ensure overseas goods face a comparable carbon price to UK-produced goods
• Will operate as a tax, with reporting and payment obligations managed through HMRC
• Will initially apply to direct emissions only, with indirect emissions not expected to be included until at least 2029

The UK has also confirmed that businesses will need to register for CBAM where imports exceed a £50,000 threshold, with reporting and payment obligations beginning from 2027 (Gov.UK, 2025).

The UK threshold is monetary and based on customs value, whereas the EU de minimis is a mass threshold of 50 tonnes per year, so a business can sit comfortably below one and well above the other.

For large organisations, this means compliance cannot be managed as a single process. Businesses will need systems capable of handling multiple regulatory frameworks, timelines, and methodologies simultaneously.

How do companies report under the CBAM system?

CBAM reporting is one of the most challenging aspects for businesses.

What needs to be reported

Companies must submit detailed data on:

• Embedded emissions in imported goods
• Production processes
• Energy usage
• Carbon intensity metrics

Why data quality matters

CBAM is not just about reporting data, it is about reporting accurate and auditable data.

The latest Circularity Gap Report highlights that inefficiencies and poor data visibility contribute significantly to value loss across supply chains. Without reliable data, businesses risk:

• Non-compliance
• Financial penalties
• Reputational damage

The shift from estimation to precision

Many organisations initially rely on estimates. However, as CBAM matures, regulators will expect:

• Verified data
• Standardised methodologies
• Full traceability

This mirrors broader trends across sustainability reporting and compliance.

Understanding the CBAM timeline and transitional phase

CBAM is being introduced at different stages across the EU and UK, creating a more complex timeline for businesses operating across both markets.

EU CBAM transitional phase (2023–2025)

The EU CBAM began with a transitional phase, which ran from 1 October 2023 to 31 December 2025. During this period, businesses were required to report on embedded emissions but faced no financial obligations under the regulation, and no certificates were bought or surrendered. The first reporting deadline for importers fell on 31 January 2024, marking the start of a new era of carbon transparency across international trade. This phased introduction was designed to give businesses time to adapt, while enabling regulators to refine methodologies and improve data accuracy ahead of the definitive regime. That preparation period has now ended: since 1 January 2026, the EU CBAM has applied in full.

EU CBAM definitive regime and future developments (from 2026)

Since 1st January 2026, the EU CBAM has moved from reporting to paying. Only authorised CBAM declarants may import CBAM goods above the threshold, and importers must now declare the embedded emissions of their imports and surrender the corresponding number of certificates each year, priced against EU ETS allowance auction prices. The Omnibus I amendment, reshaped how this applies in practice: a single de minimis threshold of 50 tonnes of CBAM goods per importer per calendar year replaced the previous per-consignment value approach, exempting an estimated 90% of importers while still capturing around 99% of the emissions in scope. Electricity and hydrogen remain in scope at any volume, with no de minimis applying. Where a carbon price has already been paid in the country of production, the corresponding amount can be deducted from the CBAM obligation.

Although liability accrues on 2026 imports, the first real financial flows land in 2027. Certificate sales open on 1st February 2027, and from that year declarants must hold certificates covering at least 50% of their accrued emissions at each quarter end.

Further expansion is under negotiation but not yet law. Proposals to extend CBAM to a range of steel- and aluminium-intensive downstream products, alongside strengthened anti-circumvention measures and a Temporary Decarbonisation Fund, are moving through the EU legislative process, with the newly covered sectors proposed to begin inclusion from January 2028. Businesses in these supply chains should treat this as a planning signal rather than a settled requirement, and monitor the outcome of the ongoing negotiations.

UK CBAM implementation timeline (from 2027)

In contrast, the UK will introduce CBAM from 1^st January 2027, without a formal transitional reporting-only phase.

Instead, the UK approach moves directly to a tax-based system, where businesses will need to both report emissions and pay a carbon-adjusted charge on in-scope imports.

The UK model will initially focus on direct emissions, with indirect emissions not expected to be included until at least 2029, reflecting a more gradual expansion of scope over time.

What this means for businesses

This divergence in timelines creates a dual challenge for large organisations operating across multiple markets.

While the EU framework allows for a period of adjustment and system development, the UK model forces businesses to be fully prepared for both reporting and financial obligations from the point of introduction.

Taken together, this signals a clear direction of travel. Regardless of region, businesses need robust, verifiable emissions data and scalable processes across their supply chains to remain compliant and competitive.

The business impact, cost, risk, and compliance

CBAM introduces both challenges and opportunities.

1. Increased compliance complexity

Businesses must now manage:

• Multi-region regulations
• Evolving reporting standards
• Detailed emissions data

2. Financial exposure

Carbon-intensive supply chains will face higher costs, particularly where emissions are poorly understood or managed.

Based on OECD modelling, CBAM could generate approximately €14.7 billion annually in carbon-related charges, highlighting the scale of potential financial exposure for businesses operating across carbon-intensive supply chains (OECD, 2025).

3. Supply chain risk

Lack of visibility across suppliers increases the risk of:

• Inaccurate reporting
• Unexpected costs
• Disruption

4. Strategic opportunity

Businesses that invest early in data, systems, and supplier engagement can:

• Reduce costs
• Improve resilience
• Position themselves as preferred partners for lower-carbon supply chains, attracting buyers with their own decarbonisation targets

Gain competitive advantage

How CBAM connects to the circular economy

CBAM is not just a compliance mechanism. It is part of a broader shift towards circularity.

Learn more about circular economy models.

Reducing dependence on virgin materials

The Circularity Gap Report 2026 highlights that the global economy remains overwhelmingly linear, with most materials coming from virgin sources. This drives both emissions and value loss.

Explore more on the global circularity gap

Improving resource efficiency

CBAM reinforces the need to:

• Use materials more efficiently
• Reduce waste
• Extend product lifecycles

These are core principles of the circular economy.

Linking carbon and value

The report shows that value lost is not marginal but systemic, driven by inefficient use of materials and energy. The report shows that any value lost is not marginal but systemic, driven by inefficient use of materials and energy.

By pricing carbon, CBAM helps make these inefficiencies visible, encouraging businesses to retain value rather than lose it through waste and emissions.

A broader sustainability context

Global indicators such as Earth Overshoot Day and global resource consumption trends highlight the urgency of reducing environmental impact.

CBAM is one piece of a much larger transformation.

How Reconomy support CBAM compliance

Navigating CBAM requires more than basic compliance. It requires expertise, systems, and a strategic approach.

Reconomy, through its specialist brand Valpak, supports businesses with:

• Emissions data collection and validation
• CBAM reporting and compliance
• Supply chain transparency
• Integration with broader ESG strategies

This aligns with Reconomy’s mission to close the gap between sustainability ambition and practical delivery.

Why expert support matters

CBAM is complex, and the risks of getting it wrong are significant.

Working with a specialist partner helps businesses:

• Improve data accuracy
• Reduce compliance risk
• Build scalable systems
• Stay ahead of regulatory change

To summarise

CBAM represents a fundamental shift in how carbon is managed within global trade. It introduces new reporting requirements, cost implications, and expectations around transparency.

For large businesses, the biggest challenge is data. Without accurate, end-to-end visibility, compliance becomes difficult and risk increases.

At the same time, CBAM creates an opportunity. Businesses that invest in better data, stronger systems, and more efficient supply chains can reduce costs, improve resilience, and gain a competitive advantage.

Becoming CBAM compliant

CBAM is not just another regulation. It is a signal of where global trade and sustainability are heading.

The businesses that treat CBAM as a data and strategy challenge today, rather than a compliance checkbox tomorrow, will be the ones best placed to compete, control costs, and stay competitive in a rapidly changing regulatory environment.

Reconomy connects you with Valpak’s expert compliance and data services to help you navigate CBAM with confidence and build a more resilient, transparent supply chain.