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The paper trail: reporting burdens, hidden costs, and regulatory coherence
With the definitive phase of CBAM now in force, the conversation has shifted from preparation to execution. The transitional period of 2023-2025 offered importers a chance to build systems and engage suppliers, and the first reporting obligations with the purchasing mechanism of CBAM certificates applies for all imports from 2026 and will be submitted no later than 30 September 2027. i In the previous issue we discussed what the regulation was and what signals it sends. In this issue, we will take a deep-dive into the actual reporting as well as the costs, both direct and indirect.
By Josef Samak, ESG Specialist, HARALD PIHL
The cost of getting it right At the heart of CBAM is a deceptively simple question: how much CO 2 was emitted to produce this tonne of goods? The answer determines whether the regulation costs a few euros per tonne or much more. Getting that answer right requires data from the supply chain, verified by an accredited third party, and using EUprescribed methodology. ii Where any part of that chain is missing, default values are used instead, but they are designed to be punitive, carrying a surcharge that rises from 10 % in 2026, 20 % in 2027, and up to 30 % by 2028. iii
What are embedded emissions? The official definition in Regulation( EU) 2023 / 956 is precise: embedded emissions are the direct emissions
“ The regulation rewards those who engage with it”
– Josef Samak, ESG Specialist, HARALD PIHL
28 Stainless Steel World May 2026 www. stainless-steel-world. net