CBAM: dialogue with suppliers is crucial for businesses

From 1 January 2026, CBAM will require the establishment of a comprehensive internal process, to be developed in advance, in a manner appropriate to the impacts in terms of costs, risks and administrative burdens on individual organisations.

The first area concerns the impact assessment. Businesses will need to calculate the cost of the CBAM on imported products by simulating the effects of applying default values or, where practicable, actual values. Comparing the two scenarios will be essential to understanding the potential cost of the mechanism. For default values, the exercise is simpler, as it is sufficient to apply the parameters provided by the Commission (which, incidentally, have recently been updated and corrected). A critical point: the definition of the non-preferential origin of goods in accordance with the relevant rules laid down by EU legislation.

We know, however, that default values provide inaccurate data. By contrast, actual values require a great deal of effort: in fact, the operator of the non-EU production plant must commit to establishing a proper procedure for monitoring and verification, promptly engaging an accredited verifier, and organising site visits and checks in good time for the 30 September reporting deadline.

It has only been possible to obtain the qualification of accredited verifier since 1 September (as at 24 September, there was only one registered verifier), and it was only last August that the Commission’s Guidance for non-EU operators and verifiers was published. In other words, anyone wishing to obtain the 2026 emissions certification in good time will have to act quickly.

At the same time, from 1 January 2026, the issue of provisioning for the CBAM cost in the accounts will need to be addressed, and it will be necessary to determine, on a case-by-case basis, whether it is possible to use the present values that have not yet been certified.