EU CBAM: 10 Common Misconceptions Importers Should Avoid

The End of the EU CBAM Transitional Period

The transitional period of the EU Carbon Border Adjustment Mechanism (CBAM) is nearing its end, giving way to the definitive phase, which is expected to begin on 1 January 2026.

This transitional phase has served as a learning period for the multiple stakeholders involved. However, it has also been the source of various misconceptions about the mechanism, among both importers and non-EU manufacturers.

For EU importers, the transitional phase introduced quarterly reporting obligations. For many, CBAM only came onto their radar after they were notified by their respective competent authorities about these new compliance requirements. As they submitted their first reports, uncertainties around key aspects of the mechanism began to emerge, complicating the compliance process. Additionally, regulatory changes under the Omnibus package were announced, adding to the confusion.

This blog post aims to clarify ten common misconceptions to help importers minimize compliance risks and gain a better understanding of CBAM’s key features before the definitive phase begins.

1. I have to collect quarterly actual emissions data from suppliers

While importers must report quarterly during the transitional period, the default reporting period for third-country operators is the (European) calendar year. This means non-EU suppliers don’t need to report emissions quarterly — annual reporting is sufficient, unless modifications are made during the year. This misunderstanding has led to communication challenges between importers and suppliers, as importers frequently requested quarterly emissions data, despite annual reporting being the recommended practice.

The reason why twelve months is the default reporting period for operators is because a full year allows operators to gather data that accurately reflects the annual operations of their installations, including any disruptions from planned shutdowns (e.g., for maintenance) and start-ups. A full year also helps mitigate data gaps, such as by taking meter readings before and after any missing periodic data points.

2. I will have to continue reporting both direct and indirect emissions

During the transitional phase, importers must report both direct and indirect emissions for all goods. However, in the definitive phase, only cement and fertilisers will have both types of emissions covered.

3. If I import CBAM goods from the UK, I don’t have CBAM obligations

Although the UK was previously part of the EU Emissions Trading System (ETS), it launched its own ETS after Brexit. Therefore, imports of CBAM goods from the UK are subject to CBAM obligations. That said, if the EU ETS and UK ETS are linked in the future —as both parties have indicated is their intention— UK exporters would be exempt from EU CBAM obligations — including financial obligations starting in January 2026. Reciprocally, EU exporters would also be exempt from the UK’s own CBAM, scheduled to take effect in 2027.

4. If I import CBAM goods from Switzerland, I must comply with CBAM

In principle, all non-EU countries fall under CBAM obligations. However, Switzerland’s ETS has been linked with the EU ETS since 2020, meaning imports of CBAM goods from Switzerland are exempt. A similar situation applies to imports from members of the European Economic Area (EEA), who participate in the EU ETS and are therefore also exempt from CBAM obligations.

5. I can only collect data from my suppliers via the CBAM communication template

The CBAM Communication Template is an optional tool provided by the European Commission to help third-country operators (non-EU suppliers) determine embedded emissions using the EU methodology.

It includes a worksheet called “Summary_Communication” that can be shared with EU importers. However, the use of this tool is not mandatory — suppliers may use alternative resources, such as the Carbon Glance tool for manufacturers, to calculate and share their emissions data, as long as it aligns with EU requirements.

6. My supplier will be liable in case of incorrect or insufficient information

Under the EU CBAM, liability rests with the CBAM declarant — either the importer or the indirect customs representative, depending on who lodges the customs declaration. Suppliers are only subject to commercial liability or to any liability privately agreed upon in a contractual arrangement between the parties.

7. As an indirect customs representative, I’m not obliged to deal with CBAM obligations

If the importer is established outside the EU, indirect customs representatives are obliged to report under CBAM. If the importer is within the EU, the indirect customs representative acts as the CBAM declarant only if it agrees to take on the reporting obligations. If it does not agree, it must inform the importer that they are responsible for compliance.

8. I don’t need to collect data from suppliers since I will be able to use default values again during the definitive period

During the transitional phase, the use of default values was permitted only until July 2024. Due to regulatory uncertainty introduced by the announced CBAM reforms —particularly concerning the new 50 tonnes de minimis threshold— some national competent authorities (NCAs) allowed the continued use of default values until the end of the transitional phase. During the definitive phase, the use of default values will be permitted again. However, if importers decide to rely on default values during the definitive period, they will face higher CBAM costs, as these values will be intentionally punitive to incentivize the reporting of actual emissions.

9. I won’t have to pay for my 2026 emissions since no certificates will be sold that year

Although CBAM certificates will not be sold until February 2027 (as per the Omnibus CBAM reforms), authorised CBAM declarants will still be financially liable for the emissions embedded in their 2026 imports. In other words, the delay in certificate sales does not remove the obligation to pay for 2026 emissions — it only postpones the date when importers are required to buy the certificates.

Importantly, CBAM financial obligations will not be fully applied starting in 2026. Instead, the obligation will increase progressively over time, in line with the phase-out of free allocation under the EU Emissions Trading System (EU ETS). This means that the amount importers must pay will be adjusted to reflect the level of free allowances an EU producer would receive for manufacturing the same goods domestically. To make this adjustment, CBAM benchmarks will be established for each covered good. These benchmarks will be based on a combination of EU ETS product benchmarks, since:

Only a limited number of ETS benchmarks currently exist, and
These benchmarks are not defined per CN (Combined Nomenclature) codes, which CBAM uses.

As a result, the importer’s financial obligation will not be calculated as 2.5% (the CBAM obligation for 2026) of their declared emissions, as is commonly assumed. Instead, this percentage will be used to reduce the CBAM benchmark for each specific CBAM good. In other words, it lowers the share of emissions that are considered covered for free, reflecting the gradual phase-out of free allocation under the EU ETS.

10. I will be able to re-sell my CBAM certificates

Unlike EU allowances (EUAs) under the EU ETS, CBAM certificates won’t be tradable. However, authorised CBAM declarants will be able to sell unused certificates back to the competent authority before they are cancelled.

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