The Carbon Border Adjustment Mechanism (CBAM) is no longer a future regulation, it’s live now, and imports entering the EU are already accruing future carbon costs. As we move towards the CBAM definitive phase, businesses importing CBAM goods need to understand their obligations, reporting requirements, and future financial liabilities.
At RENSAT, we speak with importers every day who are trying to understand what CBAM compliance in EU means for their business. Here are the most common questions we receive from companies about importing steel, aluminium, fertilisers, and other CBAM-covered goods.
What is a CBAM authorised declarant?
A CBAM authorised declarant is an entity authorised to import CBAM goods and fulfil CBAM obligations within the EU.
Under the definitive phase of CBAM, authorised declarant status becomes increasingly important because only authorised entities can manage certain CBAM obligations and certificate purchases.
Can RENSAT act as my CBAM declarant?
Yes. Many businesses do not have the internal resources to manage CBAM requirements themselves. RENSAT being a CBAM declarant can support importers with their CBAM obligations, helping ensure accurate reporting, supplier engagement and compliance management.
| Representation Status | Who raise the import declaration | Import Clearance on Behalf of | Responsibility of customs debt | Responsible for CBAM obligations |
| Without Representation | Importer | Importer | Importer | Importer |
| Direct Representation | RENSAT | Importer | Importer | Importer |
| Indirect Representation | RENSAT | RENSAT | RENSAT and Importer | RENSAT – (Upon Agreement) |
This allows businesses to focus on trading while reducing administrative burden and compliance risk.
When do I pay CBAM?
You pay nothing in 2026, but your 2026 imports are already creating the liability. Certificate sales open 1 February 2027. So, you must hold certificates covering at least 50% of your embedded emissions at the end of each quarter, then surrender the full year’s certificates by 30 September of the following year.
To know more about the impact of CBAM on importers, Read Our Blog!
What is the CBAM 2027 deadline?
30 September 2027 is the key date. By then, authorised CBAM declarants must submit their first annual CBAM declaration and surrender certificates covering everything they imported during 2026.
Certificate sales themselves open on 1 February 2027. So, 2026 is the first year your imports carry a cost, but the cash leaves in 2027, which is exactly why the liability building up now is easy to miss.
What supplier emissions data do I need for CBAM?
CBAM supplier emissions data is one of the biggest challenges facing importers.
Businesses must obtain emissions information from manufacturers and suppliers to support accurate reporting.
This often requires collaboration across multiple countries, languages and supply chains.
RENSAT regularly assists importers in gathering and validating supplier emissions data as part of their broader CBAM compliance strategy.
Can I use CBAM default values?
Yes, where you don’t have actual verified emissions data from your supplier, you can use the EU’s default values. The catch is they’re set conservatively, so they almost always produce a higher emissions figure, and a higher certificate cost, than accurate supplier data would.
They’re also rising roughly 10% in 2026, 20% in 2027, 30% from 2028. That ramp is why getting real data from suppliers early pays off, every tonne you can substantiate is a tonne you’re not overpaying for.
How much do CBAM certificates cost?
CBAM certificate prices track European Union Emissions Trading System (ETS) auction prices with a quarterly average in 2026, moving to a weekly average from 2027. Because the price floats with the carbon market, your eventual cost isn’t fixed today.
Importers should begin assessing their carbon exposure now because CBAM 2026 imports are already building the liability you’ll settle in 2027.
What are the CBAM penalties for non-compliance?
Penalties apply when you fail to surrender enough certificates (set by member states, broadly aligned to the ETS excess-emissions penalty).
Late reporting or failure to keep accurate documentation can have serious repercussions.
Which sectors are most affected?
CBAM steel and aluminium importers are among the businesses most affected by the regulation along with CBAM fertiliser imports since they can involve complex emissions calculations.
Steel products fall squarely within CBAM’s scope, making accurate emissions reporting and cost forecasting critical.
Since aluminium manufacturing processes consume large amounts of energy, emissions calculations will significantly influence the future cost of CBAM.
Preparation in advance can assist companies to minimise risks and increase visibility in their supply chains.
What happens during the CBAM definitive phase?
In the CBAM definitive phase, there are financial obligations as well as reporting obligations.
Importers will have to plan for buying certificates, calculating emissions and compliance processes.
What should importers do now to prepare for CBAM 2026?
The best preparation strategy includes:
- Identifying CBAM-covered products
- Mapping supply chains
- Collecting supplier emissions data
- Understanding future certificate costs
- Reviewing importer responsibilities
- Establishing a long-term compliance process
Because CBAM 2026 obligations are already influencing future costs, waiting until the last minute can create unnecessary risk.
How can RENSAT help with CBAM compliance?
CBAM is becoming a permanent part of international trade.
RENSAT is an authorised CBAM declarant with offices both in London and Calais to guide you through all the steps needed to comply with CBAM requirements, including informing importers about their responsibilities, managing supplier information, complying with the reporting obligation and supply our CBAM declarant number to import CBAM goods.
Whether you are a steel importer, aluminium importer, fertiliser importer or a business importing multiple CBAM goods, RENSAT can act as your authorised declarant by holding the status, filing the declaration and managing supplier data.
If you’re looking for a trusted partner to support you with CBAM, Book a Call Today!