What’s Changed?
The Carbon Border Adjustment Mechanism (CBAM) continues to evolve, and the recent Simplification Regulation, published on 20 October 2025, introduces important changes that will affect businesses across Europe. At Supply Plus, we’re committed to helping our partners navigate these updates during both the Transitional and Definitive periods.
Key adjustments include:
- Extended Deadline: CBAM declarations for 2026 imports are now due by 30 September 2027.
- Exclusions Introduced:
- EU-origin precursor materials are no longer included in emissions calculations.
- Indirect emissions are excluded for iron, steel, and aluminium products.
- Downstream finishing operations—such as plating and powder coating—are now excluded.
- Carbon Price Deductions: Carbon prices paid in third countries (including the UK) may be deducted from CBAM liability.
- Mandatory Verification: Actual emissions data must be verified by an approved accreditation body before being used in CBAM declarations.
What Does This Mean for Businesses?
While these changes simplify certain aspects of CBAM compliance, they also introduce new requirements. For example, emissions data verification will become mandatory, but the EU has yet to publish the verification framework or appoint accredited bodies. This means businesses cannot currently provide verified emissions data for products supplied from 1 January 2026.
Additionally, supporting documents that clarify these rules are still pending. Until these are released, forward planning remains challenging.
Scenario Planning
To help our customers prepare, we’ve modelled potential CBAM financial impacts for a sample product. Based on current assumptions, the best-case scenario suggests an impact of approximately €0.14 per product. However, several critical details remain unresolved:
- Verification rules are not yet published.
- Benchmarks leaked earlier have been discredited by the EU.
- Adjustments for third countries with existing carbon pricing regimes are still undefined.
Our Commitment
Supply Plus is actively working with our supply chain to ensure emissions data can be verified as soon as practical. We will continue to monitor developments and share updates as the EU releases further guidance.
In the meantime, we welcome questions and input from our partners as we navigate this evolving regulatory landscape together.
Contact us: Supply Plus
