CBAM: Must-Knows for Q1 2026
The European Union’s Carbon Border Adjustment Mechanism (CBAM) moved into full implementation on 1 January 2026, following a package of regulatory clarifications released in late December.
This blog summarises the key actions businesses must take ahead of the end of Q1 2026.
Authorised Declarant Registration: An Essential Requirement
Any company subject to CBAM obligations must obtain Authorised Declarant status by 31 March 2026 to continue importing covered products into the EU.
This process establishes an EU-wide CBAM importer register that customs authorities across Member States will increasingly rely upon. Businesses that fail to apply in time risk having shipments refused or held at the border, creating immediate operational and supply chain disruptions.
Evidence of this is already emerging, with some importers experiencing customs delays and blocked consignments in EU jurisdictions.
Customs Coding: Importers Must Use
When clearing goods through customs, importers must declare the appropriate TARIC codes to reflect their CBAM position. The most relevant codes are:
- Y128 – Authorised Declarant status approved
- Y238 – Authorised Declarant application submitted
- Y137 – De minimis exemption for imports below 50 tonnes
Gaining access to CBAM portals and completing the Authorised Declarant applications is a resource-intensive exercise, requiring detailed corporate information, supply chain mapping, and emissions-related data.
Submitting applications as early as possible is critical avoid last-minute issues.
Understanding Future CBAM Costs
Although companies will not be required to purchase CBAM certificates until 2027, emissions data reported in 2026 will directly determine future financial liabilities.
As a result, robust cost modelling and forward planning have become a core part of CBAM compliance.
Factors Driving CBAM Cost Risk
Several aspects are increasing uncertainty around CBAM exposure:
- Data verification rules: While many suppliers engaged during the Transitional Phase, only a limited number currently meet the formal certification requirements needed to continue submitting primary emissions data.
- Incomplete supplier data: Where verified data is unavailable, companies may need to rely on default values, which typically result in higher CBAM charges.
- Updated CBAM benchmarks: Newly issued benchmarks have improved alignment with the EU Emissions Trading System (ETS) but have also made emissions calculations more complex.
Without a clear strategy for managing supplier data, verification requirements, and benchmark application, businesses face a heightened risk of unplanned CBAM costs.
How RLG Supports CBAM Compliance
RLG works with CBAM-obligated businesses to manage compliance requirements end to end, including:
- Specialist support for Authorised Declarant applications, ensuring submissions are accurate, complete, and submitted on time
- CBAM financial forecasting, using supplier information and purchase order data to assess future cost exposure
- Supplier engagement and data collection, facilitated through our online CBAM survey platform
- Data readiness and pre-verification, preparing emissions data for external assurance with our trusted third-party verification partners
To learn more about our CBAM services, visit our website or contact us directly here.
