The European Association of Non-Integrated Metal Importers & Distributors (EURANIMI) has warned that significant operational challenges are already arising in the implementation of the EU’s Carbon Border Adjustment Mechanism (CBAM).
Under current rules, importers must declare embedded emissions for goods imported during 2026 by September 30, 2027, and surrender the corresponding CBAM certificates. These emissions must be calculated using verified actual emissions generated during production throughout the 2026 calendar year.
However, EURANIMI noted that emissions verification at non-EU production facilities can only begin from January 2027 onward, effectively compressing global certification activities into an eight-to-nine-month window.
Limited verifier capacity risks widespread reliance on default values
Initial CBAM certification requires full on-site technical audits. According to the association, the global pool of accredited verifiers currently lacks sufficient capacity to complete assessments for installations across all CBAM-covered sectors within the available timeframe.
Where verification cannot be completed in time, importers are required to apply default CBAM emission values, which are frequently significantly higher than actual emissions levels.
Commercial uncertainty affects contracts and pricing decisions
The lack of clarity surrounding verified emissions availability is already creating commercial risks for importers supplying EU manufacturing industries.
Contracts covering deliveries in 2026 and 2027 must be negotiated without certainty regarding final carbon adjustment costs. Importers face a choice between pricing based on estimated real emissions, risking higher liabilities if verification is delayed, or applying conservative pricing assumptions using default values, potentially making products uncompetitive.
Estimated CBAM costs may range between €0-100/mt when verified emissions are accepted but could rise to €600-800/mt if default values apply, regardless of actual producer performance.
EURANIMI warned that this dynamic risks distorting competition during CBAM’s early implementation phase, as market outcomes may increasingly depend on regulatory risk tolerance rather than genuine emissions efficiency.
Industry calls for extension of declaration deadline
To address these structural constraints, EURANIMI has called on the European Commission to extend the deadline for verified emissions declarations to December 31, 2027.
According to the association, granting installations a full year to complete verification would increase the use of actual emissions data, reduce reliance on punitive default values, improve price transparency and limit financial shocks, particularly for SMEs.
EURANIMI emphasized that such an adjustment would not weaken CBAM’s environmental objectives but would instead strengthen the mechanism’s credibility by aligning regulatory timelines with realistic global verification capacity and ensuring that carbon costs more accurately reflect real emissions performance.
