CBAM Went Live in January and Almost Nobody Pays This Year. That Is the Problem.

The European Commission’s own page states it in one line: as of 1 January 2026, CBAM is applicable under its definitive regime. The transitional period, in which importers filed quarterly reports and paid nothing, is over.

What has not started is the paying. No CBAM certificate can be bought before February 2027. The first annual CBAM declaration, covering every affected import made during 2026, is not due until 30 September 2027.

So the mechanism that has been described for three years as an incoming cost is, in its first live year, an incoming data obligation with a twenty-one-month lag before anything is owed. That lag is the reason a large number of importers will arrive at their 2027 filing unable to complete it, and it is worth being precise about why.

What actually changed on 1 January

The gate moved to the front. Since 1 January 2026, according to Germany’s DEHSt, the emissions trading authority that administers CBAM there, “only authorized CBAM declarants may import CBAM goods into the customs territory of the EU.”

CBAM goods are the Annex I list: cement, iron and steel, fertilisers, aluminium, electricity and hydrogen. Authorisation is not a formality granted at the border. It is a status applied for in the CBAM registry, and without it the import cannot lawfully proceed.

The gate also catches parties who would not describe themselves as importers. DEHSt’s guidance requires an indirect customs representative to hold authorised declarant status as soon as it wants to submit customs declarations for CBAM goods, without waiting to cross any volume threshold. A customs agent or logistics provider filing on a client’s behalf is inside the regime on that client’s goods.

There is a de minimis. Regulation (EU) 2025/2083, the CBAM simplification regulation, formally adopted on 8 October 2025 and in force from 20 October, replaced the old €150-per-consignment exemption with a single mass threshold of 50 tonnes of net mass per importer per calendar year. Below that, for cement, iron and steel, fertilisers and aluminium, no authorisation is needed. The threshold does not apply to hydrogen or electricity at all: importers of those need authorised status regardless of volume.

That figure was calibrated rather than chosen for administrative convenience. The Commission’s stated design intent was that the threshold would exempt 90% of importers while still covering 99% of emissions, which is a claim about how concentrated CBAM-relevant emissions are among a small number of large importers. The exemption was never meant to release material volume. The same design also says the 50-tonne figure will be increased if it stops ensuring that at least 99% of emissions are covered, so a threshold defined by the coverage it has to preserve is one that adjusts to behaviour, including the behaviour of importers restructuring to sit beneath it.

The data being counted is not yours

This is the part that does not survive being left until 2027.

CBAM prices the emissions embedded in a good: the greenhouse gases released producing it, at the installation where it was produced, attributable to the specific quantity you imported. The obligation lands on the importer. The measurement happens at a third party’s plant, usually outside the EU, during the year the goods were made.

The Commission adopted a package of implementing acts through November and December 2025 covering, among other things, verification principles and accreditation, the calculation methods for goods, and the establishment of default values. Default values exist for a reason: an importer who cannot obtain actual data from a supplier is not left without a number. But the default route means declaring a figure derived from the Commission’s assumptions about your supplier’s production rather than from your supplier’s production.

Either way, the choice is being made now, silently, by whether anyone asked. A supplier that received a data request in January is generating records against it, a supplier that received nothing is not, and 2026 will not be available for re-measurement in September 2027.

For companies importing from suppliers with no prior EU carbon-reporting exposure, which describes a large share of the relevant trade from Asia, the request itself is often the harder half. It asks a plant manager for installation-level process emissions data, in a defined format, verifiable by an accredited party. That is a months-long conversation the first time it happens, and it does not compress.

It also has no obvious owner. Procurement holds the supplier relationship but not the emissions expertise, sustainability holds the expertise but not the commercial leverage, and trade compliance holds the filing but sees the supplier only through a customs declaration. In most organisations the request stalls in the gap between those three rather than at the supplier’s end, which is worth checking before concluding that a plant abroad is being unresponsive.

The boundary is scheduled to move

On 17 December 2025, the Commission proposed extending CBAM’s scope from 1 January 2028 to 180 additional downstream products with high steel or aluminium content, alongside strengthened anti-circumvention provisions. The sectors named as most affected are machinery, hardware and fabrications, vehicle parts, domestic appliances and construction equipment. Ninety-four per cent of the additional products are intermediate industrial goods rather than consumer items.

This is a proposal. It has to pass the European Parliament and the Council, and its final scope may differ from the draft. It should not be reported as settled law, and nothing in a 2026 compliance plan should assume it.

It should, however, change how a company reads its current exemption. An importer of finished machinery is outside CBAM today and inside the proposed 2028 list. The distance between “not in scope” and “in scope” is one legislative cycle, and the supplier relationships that would have to produce the data are the same ones being built, or not built, this year.

Where this meets the reporting you already do

Most organisations are running CBAM as a customs and trade problem and CSRD as a sustainability-reporting problem, usually in different functions, on systems that do not talk to each other.

They are asking the same suppliers for overlapping data.

ESRS E1 requires disclosure of Scope 3 emissions, and for a manufacturer or importer the largest Scope 3 category is almost always purchased goods and services, meaning the emissions of the things you bought. We have written separately on what Scope 3 under CSRD actually demands. CBAM asks a narrower and deeper version of the same question: not a category total, but embedded emissions per good, per installation, verified.

The granularity differs, but the counterparty is the same. A supplier who has already been asked to produce verified installation-level emissions data for a CBAM declaration has, in the process, produced the underlying evidence for a Scope 3 figure that would otherwise rest on a spend-based estimate. A company that runs the two projects separately asks that supplier twice, accepts two different answers, and reconciles them by hand at year-end.

The structural fix is the same one that fixes every other version of this problem: hold the disclosures as data, in one place, with the provenance attached — which supplier, which installation, which period, verified by whom — and generate each report from it. CBAM is not one of the standards Socious Report files for, but the supplier-emissions dataset it depends on is exactly the one Socious Report is built around.

If you want a fast read on where that dataset currently stands, our free CSRD readiness check scores seven dimensions in twelve questions and takes about three minutes. It will tell you whether your value-chain data is in a system or in an inbox, and that answer is the same one that decides your September 2027 CBAM filing.