Webinar recap | EU CBAM: Key updates and how to avoid costly pitfalls

The 50-tonne threshold is annual, not quarterly. It comes from the recent ‘Omnibus’ simplification proposal from the EU Commission and applies, on a cumulative basis, per importer per year. So, if you import less than 50 tonnes of CBAM goods annually, you are exempt from CBAM-related obligations.

As present, no. These types of products are not currently in scope of CBAM. Today, CBAM focuses on materials like iron and steel, aluminium, cement, fertilisers, hydrogen, and electricity. However, this is exactly the type of product that could be affected in the future under the proposed extension to downstream goods, since it contains steel. In short, not in scope today, but potentially in the future.

There’s no official consolidated Excel file or mapping list available from the European Commission at present. The information on precursors is primarily provided in the CBAM guidance documents, where specific precursor materials are defined by sector. In practice, companies often need to interpret this and map it internally, based on their products and supply chains.

There’s no confirmed timeline yet, but the European Commission has already indicated that an extension to downstream products is under consideration. Based on current signals, this will potentially happen in 2028, before the full phase-in scheduled for 2034. So, while not immediate, companies should already anticipate this — especially if they import finished or semi-finished goods containing CBAM materials.

The importer – or the authorised CBAM declarant – remains responsible for the data submitted. However, this does not mean you need to physically audit each supplier yourself. In practice, emissions data is calculated by the supplier and then verified by accredited third-party verifiers. What companies need to do is ensure the data is robust and compliant. And yes, partners like Kuehne+Nagel can support the process, particularly in structuring supplier engagement, collecting data, and ensuring compliance. However, the regulatory responsibility remains with the declarant.

The EU Commission has put together an Authorisation Management Module (AMM) related to CBAM authorisations. This module facilitates the entire process from start to finish. This begins with the initial authorisation requests submitted by applicants through to the consultation process between the necessary authorities and the Commission, culminating in a decision to grant (or refuse) the authorisation. 

Yes, to some extent, this is normal. When applying for authorised CBAM declarant status, authorities may request financial information to assess the reliability and financial standing of your company. This is similar to other customs authorisations, where authorities want to ensure the company can meet its obligations.

Yes, CBAM is linked to the importing legal entity, not the group as a whole. Each legal entity acting as an importer of record needs to be registered separately as an authorised CBAM declarant.

Yes, in principle, independence is needed. The supplier calculates emissions, and verification should be carried out by an independent, accredited verifier. This separation ensures credibility and compliance with the CBAM requirements.

The logic is similar, but it becomes more complete and stricter. During the transitional phase, quarterly reports were mainly for data collection and familiarisation. In the definitive phase, the annual declaration becomes a formal, binding report that includes verified emissions data and the number of certificates to be surrendered. So, their structures are comparable; however, the level of accuracy, verification, and financial impact is significantly higher.

No, quarterly reporting no longer applies in 2026. From 1 January 2026, we move into the definitive phase, which means reporting becomes annual, not quarterly. That means imports from 2026 will be declared in the annual CBAM declaration in 2027, which is when the corresponding certificates will be surrendered.

The EU Commission has now published the default values per CN code, per country. You can consult them via this webpage.

Yes, the EU has developed the CBAM Registry, which includes functionalities to support data exchange. In practice, suppliers do not automatically upload data that importers can freely access—the process is still largely driven by the importer, who needs to collect emissions data directly from suppliers. The registry is mainly used by authorised declarants to submit data, but supplier engagement and data collection still happens outside the platform, often through structured templates or tools. It’s not a fully automated supplier portal at present, as it still requires active coordination.

Yes, in practice this can happen. If the supplier cannot provide calculated emissions, the importer can support by collecting the necessary production data and applying the CBAM methodology. However, this requires very detailed input data from the supplier, and any emissions calculations need to be verified. Otherwise, default values would apply.

In the definitive phase CBAM declarations must be based on either:

• Verified emissions data, calculated using actual supplier information and validated by an accredited third-party verifier.

• Default values provided by the European Commission.

While actual (specific) emissions data may be collected from suppliers, it cannot be used for CBAM declaration purposes unless it has been independently verified. As the authorised CBAM declarant remains fully responsible for the accuracy of the reported data, the use of non-verified emissions would expose the importer to compliance and financial risks. Therefore, in the absence of verified data, default values remain the only compliant alternative.

Verification must be done by independent accredited verifiers, similar to EU ETS. There’s no fully centralised CBAM-specific list yet, but ETS verifiers are typically used.

It should be the supplier.

There’s a compliance risk if the data isn’t verified. As the authorised CBAM declarant, you remain responsible for what is reported. That’s why the objective is to progressively move towards verified data. In terms of how to get there, the supplier first needs to calculate their emissions based on the CBAM methodology, then this data can be validated by an independent accredited verifier. If the supplier isn’t familiar with CO2 calculations yet, this is quite common and in practice, companies usually support their suppliers with templates, guidance, or external partners to structure the data collection. If this isn’t possible, then default values can still be used, however, this could end up costing more in CBAM certificates.

From 2027 onwards, CBAM certificates are linked to a weekly ETS price, so, the cost is not fixed. In practice, companies won’t be able to calculate a final exact cost upfront. Instead, they need to manage it as a dynamic cost component, similar to energy or fuel prices. What we typically see is that companies work with assumptions or averages, for example, using recent ETS price trends to estimate their exposure then adjusting over time. Some also build in a buffer or margin to account for volatility. It becomes less about fixing a precise cost, and more about managing a range and updating it regularly as the ETS price evolves.

Yes, that’s exactly the right way to think about it.

CBAM certificates are not traded between companies like ETS allowances. If you have excess CBAM certificates, the resale is done back to the EU authorities, not to other companies. And even that is limited, you can only resell up to 50% of your excess certificates once per year. There is no secondary market for CBAM certificates. This is a key difference compared to ETS, which is a fully tradable market.

There are three main ways to do this:

1. Use verified emissions instead of default values: If no data is provided, default values are applied. These are usually higher and more conservative than actual values, which increases CBAM-related costs. By using real and verified emissions data from your suppliers, the declared emissions are often lower, which reduces the number of certificates required.

2. Work with suppliers with lower emissions: The carbon intensity of production can vary depending on the supplier and the country. Choosing suppliers with more efficient or lower-emission production processes will directly reduce CBAM costs.

3. Deduct carbon price already paid in the country of origin: If a carbon price has already been paid outside the EU, this amount can be deducted from the CBAM obligation, reducing the number of certificates to purchase.

CBAM and ESRS are fundamentally different in nature. CBAM creates a direct financial cost linked to CO₂ emissions. Importers must purchase certificates based on embedded emissions, which can increase the cost of goods. ESRS is a reporting framework, not a pricing mechanism. It requires companies to disclose emissions and sustainability information, but it does not create a direct cost per tonne of CO₂. 

The key is not to wait until you cross the threshold. Even if you are below 50 tonnes today, I would strongly recommend starting to prepare now by mapping your supply chain, understanding your volumes, and engaging with key suppliers. Once you exceed the threshold, you need to be fully operational, especially with emissions data and declarant status. It’s about anticipating rather than reacting