The minute
- The definitive phase began on 1 January 2026: importers must now account for the carbon in the goods they bring into the EU
- Certificate sales were pushed to 1 February 2027, and the first surrender covers 2026 imports by 30 September 2027
- Importers below 50 tonnes of CBAM goods a year are fully exempt, including from reporting
Why it matters: CBAM is the first serious attempt to price the carbon embedded in trade, and it lands directly on Brazilian exporters of steel, aluminium, cement and fertilisers.
How it works
The Carbon Border Adjustment Mechanism charges importers for the emissions embedded in certain goods, so that products made under weaker climate rules do not undercut European producers who pay for their carbon. During the transitional phase, from October 2023 to the end of 2025, importers only reported data and paid nothing.
From 2026 the obligation is financial. Certificate prices for goods imported in 2026 follow the quarterly average auction price of EU ETS allowances; from 2027 the reference becomes a weekly average.
The simplifications that matter
The omnibus package softened the start without changing the direction. The de minimis exemption removes small importers entirely, the annual declaration moved from 31 May to 30 September, and the sale of certificates only starts in February 2027, which gives exporters an extra year of practice before money changes hands.
What a Brazilian exporter should do now
Measure the carbon intensity of each exported product, not of the company as a whole; keep the evidence in a form a European client can audit; and check whether a domestic carbon price already paid can be deducted, which is exactly the argument Brazil gains once the SBCE is running.
Sources: European Commission CBAM implementing acts of 17 December 2025; ICAP.
Frequently asked questions
Who actually pays for CBAM?
The EU importer of the covered goods (steel, aluminium, cement, fertilisers, hydrogen, electricity), not the exporting company directly.
When does the certificate purchase obligation start?
From February 2027, covering 2026 imports retroactively.
Can carbon price paid at home reduce what’s owed under CBAM?
Yes, a carbon price already paid in the country of origin can be deducted from the CBAM amount.
Primary sources: Carbon Border Adjustment Mechanism overview (European Commission, 2026); CBAM definitive regime: 50-tonne threshold, certificate price and deductions (European Commission, 2026); EU adopts CBAM simplifications, Regulation (EU) 2025/2083 (ICAP, 2025).
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