The short version
CBAM — the EU’s Carbon Border Adjustment Mechanism — left its trial phase behind on 1 January 2026. The reporting-only transitional period is over; the definitive regime is in force. What softens the landing is the October 2025 Omnibus Regulation, which pushed the first certificate purchases to February 2027 and exempted small importers entirely. For a Western Balkan exporter of steel, aluminium, cement or fertilisers, that combination means one thing: 2026 is the year your data gets collected, and 2027 is the year it starts costing your customers money.
The 50-tonne rule — and why you can’t count on it
The Omnibus Regulation introduced a mass-based exemption: importers whose total net imports of covered goods stay under 50 tonnes per year are released from CBAM obligations altogether. That genuinely removes small and occasional importers from the system.
But read it from the exporter’s side: the threshold applies to your customer’s imports, not your production. A customer buying 40 tonnes from you may be exempt this year — and over the threshold next year, or already over it because of what they buy from someone else. Any serious EU buyer of metal, cement or fertiliser inputs crosses 50 tonnes without noticing. Planning your data readiness around a customer’s exemption is planning around something you can’t see and don’t control.
What the questionnaires ask for
Requests reaching suppliers this year converge on the same substance: emissions calculated at installation level — production volumes, fuel and electricity consumption, process emissions where relevant — plus the factors used, and documentation a verifier can follow. The full breakdown is on our CBAM page, but the property that decides whether your data gets used is simple: traceability. A number without a documented origin is a number your customer’s verifier will replace with a default value.
Why defaults hurt you: when actual data is missing, importers fall back on default values set conservatively by the European Commission. Conservative defaults make your goods look more carbon-intensive than they are — and from February 2027, more expensive. Two suppliers, same product: the one with credible actual data is the cheaper one to import from.
What to do with the months left in 2026
- Start the monthly record now. Certificates in 2027 are priced on 2026 emissions. Every month without structured energy and production data is a month your customer covers with defaults.
- Reconcile against invoices. The data that survives verification is the data that matches the paperwork — electricity invoices, fuel purchases, production logs.
- Document your factors. Which emission factors, from which source, at which version. “We used a website” is not an answer a verifier accepts.
- Answer the first request well. Importers are building supplier lists this year. The suppliers who respond credibly in 2026 become the easy choice in 2027.
Where does your company stand?
Get a rough footprint estimate and the evidence checklist for a CBAM request — free, about five minutes.
Sources: Regulation (EU) 2023/956 (CBAM) as amended by the CBAM Omnibus Regulation adopted 8 October 2025. This article summarises the rules as of August 2026 and is not legal advice; always work from your customer’s specific request.