CBAM has truly begun. While the mechanism officially started in Q4 2023, as of 1 January importers must actually pay for CO₂ emissions on products in sectors such as metal, aluminium, fertilisers, hydrogen, cement and electricity.

The reason is clear. Within the EU, producers already pay for their CO₂ emissions. The European Union wants to prevent products from outside the EU from remaining cheaper simply because no comparable CO₂ costs apply there. CBAM creates a level playing field.

For many importers, however, CBAM brings major challenges. Tracking imports at line-item level, linked to suppliers and associated emissions, is almost impossible to do manually. Without automation, this quickly becomes unmanageable.

On top of that comes a second, even more complex step: verification. Importers must prove that the emission data provided by manufacturers is correct. This requires a monitoring plan, usually prepared with external support. Emissions must then be monitored for a full year and verified by an accredited verifier.

And that is exactly where the biggest bottlenecks arise

At present, very few verifiers are available. Many factories also do not yet understand what CBAM actually requires from them. Even when one factory is verified, the rest of the supply chain often remains out of scope. A finished product may have gone through multiple production steps. For example several factories in China, followed by further processing in India.

It may take until 2028 before it becomes clear across the entire chain that the end customer is facing significantly higher CBAM costs.

There is also a structural issue: capacity. Even if verifiers are appointed later this year, it is unrealistic to expect them to verify hundreds of thousands of factories worldwide in time. As a result, default values will be applied to many imports. And that? You often only find out long after the goods have been imported and sold.

This has direct financial consequences

Take the fasteners (screws) sector as an example. The difference between default values and actual emission values can increase from €80 to €500 per ton. On a product priced at €900 per ton, that is a major cost increase. Without decarbonisation, this amount could even grow to €2,000 per ton within ten years.

Market distortion also arises. Some importers have already factored in their CBAM risk and are building up large inventories, often without an immediate price surcharge. Others are doing the same, but without realising that a surcharge is inevitable. They only discover in 2027 that they must pay hundreds of euros per ton. In that scenario, business continuity comes under serious pressure.

At the same time, products with a €500-per-ton surcharge are hard to sell as long as competitors keep prices low due to a lack of awareness.

Finally, there is a critical compliance risk

Even if you believe you are working with actual emission values, an audit may still lead to rejection. In that case, the values are replaced with default values, with immediate financial impact.

The conclusion is clear: CBAM is not an administrative side issue. It requires reliable data, demonstrable compliance and smart automation.

Do you want to stay in control of CBAM, reduce risks and manage costs? Then Dubrink and Pincvision are your trusted partner for CBAM compliance, automation and insight.