CBAM guidelines for procurement

Procurement and sourcing teams are facing new tasks under CBAM. Since 1 January 2026, carbon costs add another layer of complexity to international material purchases. For a structured CBAM implementation, procurement teams play a key role at the interface between customs/compliance, supplier management and finance/controlling.

CBAM 2026: From reporting to financial management

Since 1 January, the Carbon Border Adjustment Mechanism (CBAM) has shifted from reporting to financial management. Carbon costs effects and compliance obligations are now a growing concern, especially for procurement and sourcing teams in global supply chains.

The final CBAM rules now apply to imported CBAM goods in iron and steel, aluminium, cement, fertilisers, H2 and electricity. CBAM certificates must be purchased for these goods from February 2027 onward. This creates additional costs that are still difficult to plan for today.

The implementing rules were only published shortly before they entered into force on January 1. In total, 13 regulations define the detailed implementation rules, while 3 are still outstanding. Existing rules are also expected to be amended and updated.

In addition, the overarching CBAM Regulation (EU) 2023/956 is currently undergoing amendments in the EU trilogue process. Following last year’s simplifications to the rules, its scope is now expected to be expanded to around 150 downstream goods in iron and steel and aluminium.

CBAM requirements in practice

For procurement and sourcing teams working with non-EU suppliers, this means rising costs and additional complexity. In practice, they can follow a structured implementation approach.

Identify CBAM goods and quantities

The starting point is to correctly identify whether purchased goods fall under CBAM, as well as their quantities and the timing of import.

Importing companies must submit an annual CBAM declaration – for the first time in September 2027 for the year 2026. Companies remain exempt below 50 t across all CBAM imports in a calendar year.

To ensure that CBAM data matches customs declarations, companies primarily need:

1. Systematic identification of CBAM-relevant CN codes and mapping to internal product or product group classifications;
2. Ongoing maintenance and consistent reconciliation of quantities and import dates between ERP/data systems and customs declarations.

This requires CBAM-adjusted product group and data management – in close coordination with customs and compliance functions within the company.

Determine CBAM emissions

Emission values for the goods form the basis for CBAM cost calculations. In practice, there is substantial uncertainty here, especially with data reported by suppliers.

Importers may use EU default values (with mark-ups). However, because these can lead to very high additional costs for many countries of origin and products, manufacturers’ actual values are generally the preferred option.

However, manufacturers must meet very demanding EU standards for this:

1. CBAM-compliant calculation based on the latest EU rules; in particular, the definition of production processes and units has changed compared with the transitional period;
2. Complete disclosure of all required elements, including those needed to calculate free allocation adjustments;
3. Complete evidence of auditable data for precursors, so that the share of actual emissions used is robust and defensible;
4. Auditable documentation from the monitoring plan and operators emissions report to demonstrate the methods, measurement systems and calculation factors applied;
5. Verification by an accredited CBAM verifier who confirms compliance with the applicable EU standards.

This makes securing CBAM-compliant emissions data a core supplier management task – comparable to managing price, quality or delivery risks.

Procure CBAM certificates

CBAM costs depend on the CO2 price of CBAM certificates. These are derived from the EU Emissions Trading System (ETS).

For 2026, these will be calculated retrospectively as the average for the quarter in which the CBAM goods are cleared through customs. From 2027 onward, certificates can then be purchased continuously at a weekly average price.

Because ETS prices may fluctuate significantly, the purchase of CBAM certificates is subject to substantial price uncertainty. In Q1/2026, for example, prices fell by 32% within 8 weeks, from more than EUR 90/tCO2e to almost EUR 60/tCO2e.

By 2027 at the latest, a procurement strategy will therefore be required for:

1. Product cost and pricing calculations based on forward-looking CO2 prices;
2. Hedging price volatility in order to cushion short-term spikes and long-term increases;
3. Procurement of minimum quantities required by the EU at the end of each quarter.

Comprehensive CBAM cost management and hedging of CO2 price risks therefore become essential for financial planning and controlling.

Solutions for CBAM implementation

CBAM is a cross-functional task: procurement teams are often well positioned to coordinate CBAM solutions at the interface between customs/compliance, supplier management and finance/controlling.

This requires the right foundations to be put in place:

1. Clear responsibilities and effective coordination across the different departments;
2. Adjusted processes for collecting and integrating import, emissions and carbon price data;
3. Development of expertise and resources (internal and external) to implement the new CBAM tasks.

Even though CBAM already has cost implications today, companies still have until 2027 to put responsibilities, processes and data on an EU-compliant and efficient footing.

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Sources and Further Information:

1. European Commission: CBAM – Overview
2. EU: Regulation Establishing CBAM (2023/956)

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