CBAM Moves into Its Final Phase: Implications for UK Exporters in 2026

The European Union’s Carbon Border Adjustment Mechanism (CBAM) has now moved into its most commercially impactful phase. As of January 2026, the regime has shifted from a transitional reporting-only period to its definitive stage, under which verified emissions data directly determines the carbon charges applied to goods entering the EU market. 

For UK manufacturers, fabricators, and exporters serving EU clients, this represents a significant change. Emissions reporting is no longer just an administrative requirement handled by your EU importer; it becomes a critical commercial factor affecting pricing, competitiveness, and supplier decisions. 

This briefing outlines what is changing, what your EU customers are likely to require from you, and the practical steps UK businesses should now be taking to prepare. 

What changes between the transitional phase and the definitive period? 

On 1 January 2026, CBAM entered its definitive period. During the transitional phase, importers were only required to report emissions data. 

From 2026 onward, the emissions data collected for imported goods will generate a financial obligation for EU importers. In practical terms, CBAM becomes a direct cost of importing products into the EU. 

As a result, this additional cost will increasingly affect commercial agreements, pricing strategies, and supplier selection decisions. 

Am I required to register in the EU? 

As a UK supplier, you are not required to register as a CBAM declarant. The legal obligation to submit CBAM declarations rests with the EU importer (or their indirect customs representative, where applicable). 

Your role is primarily commercial: ensuring you provide your EU customers with the required emissions data accurately, on time, and in a verifiable format so they can meet their compliance obligations. 

How does the 50-tonne de minimis threshold apply? 

CBAM provides for a 50-tonnes per year de minimis threshold per EU importer for iron and steel, aluminium, cement and fertilisers. Electricity and hydrogen are not subject to any threshold. The threshold applies to the EU importer, not the UK exporter. 

• If an EU importer imports less than 50 tonnes in total of CBAM-covered goods during a calendar year, CBAM requirements do not apply to that importer for those products. 

• If the 50-tonne threshold is exceeded, CBAM charges apply to the entire volume of covered goods imported, not just the portion above 50 tonnes. 

Although this exemption may benefit smaller importers, many EU customers expect to exceed the threshold and are planning accordingly. As a result, they will typically require emissions data from suppliers as standard. UK exporters should therefore be prepared to provide compliant CBAM data to their EU customers. 

What information must I provide? 

Prepare for more detailed data requests. EU importers will require: 

• Embedded emissions data for the products you supply, including the methodology used to calculate it. 

• Supporting documentation where relevant (for example, carbon costs incurred outside the EU). 

• Verification by an accredited independent verifier, which may include an onsite audit. 

It is important to collect data consistently, as products sold in 2026 may have been manufactured in earlier years. 

What reporting period do I need to cover? 

During the definitive period, EU reporting is on an annual basis. EU importers must submit a CBAM declaration for goods imported in 2026 by 30 September 2027. As a supplier, you may find it helpful to align your data sharing with the same annual cycle. 

What CBAM levy will apply to my product at import? 

EU importers pay CBAM based on the embedded emissions in the imported goods, adjusted according to EU benchmark rules and phase-in mechanisms. In the early years, charges are expected to be moderated to support a gradual implementation. Additionally, carbon costs already paid outside the EU may be deductible if proper evidence is provided. 

The European Commission has set benchmark values for embedded carbon for each commodity in scope when produced in Europe. The CBAM levy applies to any emissions above these benchmark values. 

How will things change? 

CBAM’s scope is expected to expand. The European Commission has proposed including a broad range of downstream iron/steel and aluminium products (around 180 additional CN codes) with a potential start date of 1 January 2028, pending adoption. 

The EU Commission continues to respond dynamically to feedback from member states, so exemptions, adjustments, and temporary suspensions may occur. Organisations like ChamberCustoms and the British Chambers of Commerce are monitoring the developments closely, helping to interpret the latest guidance for businesses. 

In the meantime, UK exporters should collect accurate emissions data, ensure it can withstand verification, and be prepared for audits. Demonstrating CBAM compliance has become a strategic advantage in maintaining credible and trusted relationships with EU customers. 

Preparing for CBAM: Next steps for UK Exporters: 

CBAM is now a real commercial factor for EU importers, and, by extension, for UK suppliers. 

Although the legal responsibility rests with EU customers, the accuracy and credibility of the data you provide will increasingly affect pricing, supplier selection, and long-term business relationships. Companies that can deliver reliable, verifiable emissions data will be better positioned to protect margins and maintain strong EU customer relationships. 

ChamberCustoms, part of the British Chambers of Commerce, helps UK exporters with: 

• Calculating embedded emissions for CBAM-covered goods 

• Developing a structured CBAM monitoring strategy 

• Providing knowledge-transfer sessions for stockists, distributors, and businesses building in-house CBAM capabilities 

CBAM is continuously evolving, and we track developments closely to deliver practical, commercially focused guidance for UK businesses trading with the EU. 

If you want to understand how CBAM affects your products, customers, or supply chains, our team is ready to discuss how we can support you. 

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