Figure 3. CBAM cost calculation formula. Based on Regulation( EU) 2023 / 956, and Implementing Regulation( EU) 2025 / 2620.
suppliers rely on the default values. These are set at the highest emission intensity observed among reporting countries for each product type, plus a surcharge of 10 % in 2026, which will rise to 30 % by 2028. iii The simplicity of defaults masks a compounding financial risk that grows as both the CBAM Factor and ETS prices move against the importer. The current default values can often be double of what they actually are, which effectively doubles the CBAM costs.
Goods already in free circulation Once CBAM-covered goods have been released for free circulation in the EU, meaning CBAM declarations have been made and obligations met, they are treated as EU goods for the purpose of the regulation. x They can be traded, warehoused, cut to length, resold, or transported within the EU
About the company
Josef Samak is ESG Specialist at HARALD PIHL, Europe’ s leading supplier of highperformance metal alloys. Founded in 1912, the family-owned company has long served some of the world’ s most demanding industries- including aerospace, energy, and medical technology- with materials engineered to perform in extreme environments. Sustainability is an integrated part of HARALD PIHL’ s governance and risk management framework. This work is led by ESG Specialist Josef Samak, a civil engineer educated at KTH with an MSc in Energy Systems. Josef is responsible for CBAM declarations, sustainability reporting, and broader compliance initiatives. without any further CBAM liability. The carbon cost has been accounted for at the point of import, and no second charge arises for domestic downstream handling.
Non-compliance: the financial and legal stakes Failure to surrender sufficient CBAM certificates carries a penalty of EUR 100 per tonne of unreported emissions, adjusted for inflation, with no upper cap. xi For those importing without authorised declarant status, the penalty is three to five times this amount. Payment of the penalty does not release the importer from the obligation to surrender the outstanding certificates.
Final thoughts The transitional period is over, and the real work begins. For importers still relying on default values or waiting on supplier data, the cost of inaction is now measurable in euros per tonne, and it compounds every year. While the total costs might not be substantial in the beginning, they will grow at a fast rate which might make certain imports completely unsustainable if reliant on default values. The good news is that the regulation rewards those who engage with it. Better data means lower costs, and lower costs mean a real competitive edge over those who don’ t bother. However, two obstacles stand in the way. The first is that manufacturers may not have the correct data available, forcing importers to fall back on default values. The second is that importers themselves may not want to put resources on how to declare correctly, which leads to the same outcome, default values and higher costs. Both scenarios penalize inaction, which will most likely lead to many importers gravitating toward European suppliers
who can provide the right data and remove the complexity entirely.
References i
Regulation( EU) 2025 / 2083( CBAM Simplification Regulation)— eur-lex. europa. eu / eli / reg / 2025 / 2083 / oj ii
CBAM Webinar( CBAM has launched- What changes for me?)— https:// customstaxation. learning. europa. eu / course / view. php? id = 1047 & section = 1 iii
Commission Implementing Regulation( EU) 2025 / 2619( laying down rules for the application of Regulation( EU) 2023 / 956 of the European Parliament and the Council as regards the establishment of default values)— https:// eur-lex. europa. eu / eli / reg _ impl / 2025 / 2621 / oj / eng iv
Regulation( EU) 2023 / 956, Art. 3( establishing a carbon border adjustment mechanism)— eurlex. europa. eu / eli / reg / 2023 / 956 / oj v
Commission Implementing Regulation( EU) 2025 / 2547( laying down rules for the application of Regulation( EU) 2023 / 956 of the European Parliament and the Council as regards the methods for the calculation of emissions embedded in goods)— eur-lex. europa. eu / eli / reg _ impl / 2025 / 2547 / oj vi
Commission Implementing Regulation( EU) 2025 / 2620( Free allocation adjustment and CBAM Factor schedule)— eur-lex. europa. eu / legal-content / EN / TXT /? uri = CELEX: 32025R2620 vii
Directive( EU) 2023 / 959( establishing a system for greenhouse gas emission allowance trading within the Union)— eur-lex. europa. eu / legalcontent / EN / TXT /? uri = CELEX: 32025R2620 viii
Commission Implementing Regulation( EU) 2025 / 2548( Certificate price calculation); European Commission news, 6 March 2026— taxation-customs. ec. europa. eu / news / first-cbam-certificate-price-be-published-7- april-2026-03-06 _ en ix
European Commission, DG TAXUD: CBAM legislation and guidance( third-country carbon price deduction— implementing act pending)— taxation-customs. ec. europa. eu / carbon-border-adjustment-mechanism / cbamlegislation-and-guidance _ en x
Regulation( EU) 2023 / 956( scope, release for free circulation, inward processing)— eur-lex. europa. eu / eli / reg / 2023 / 956 / oj xi
Directive 2003 / 87 / EC( establishing a scheme for greenhouse gas emission allowance trading within the Community)— eur-lex. europa. eu / eli / reg / 2023 / 956 / oj
Next issue …
In the next issue, we will take stock of the mid-year picture: how CBAM has affected European manufacturers’ competitiveness, whether the regulation has had a measurable effect on emissions, and how surrounding industries are navigating the new landscape.
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