CBAM 2027: How and why companies should act now
With the CBAM (Carbon Border Adjustment Mechanism), the EU is creating a new instrument that promotes climate-friendly production worldwide by bringing climate-damaging imports more into line with European environmental standards. A transition phase will apply until February 2027, but inaction would be a costly risk. In this article, we show why companies should take action now, which products are affected, and what specific changes the latest legislation will bring.
Reasons why action should be taken now:
- CBAM reports have been mandatory since October 2023
- Fines may be imposed for non-reporting (no reports, incomplete reports, or late reports will result in warnings or sanctions)
- Data collection takes time (emission data, especially for imports from third countries, is often not immediately available)
- CBAM will become subject to fees from 2027 (the first final annual report for 2026 must be submitted by May 2027, including retroactive certificate issuance)
- Demonstrate reliability to the authorities (companies that already report correctly are seen as compliant)
- Optimization of supply chains (early analysis of particularly CO2-intensive imports)
Companies that already use SAP systems for transport management or freight cost accounting can integrate CBAM requirements more easily.
Product groups: Who is affected and what else is coming?
Product groups currently affected:
| Product group | Examples / Details | KN codes (excerpt) |
| 1. Iron & steel | Semi-finished products, sheets, rods, tubes, etc. | e.g. 7206–7301 |
| 2. Aluminum | Raw aluminum, profiles, sheets | e.g. 7601, 7606, 7607 |
| 3. Cement | Cement, mixtures containing clinker | e.g. 2523 |
| 4. Fertilizers | Nitrogen fertilizers, urea, mixed fertilizers | e.g. 3102, 3105 |
| 5. Hydrogen | Pure hydrogen | e.g. 2804 10 00 |
| 6. Electricity | Electric current (applicable to physical imports) | Only relevant in special cases |
Planned expansion in 2026–2030:
Planned product group: | Examples: |
| Chemicals | Ethylene, propylene, methanol, etc. |
Plastics | Polyethylene, polypropylene, PVC, PET, etc. |
| Ceramic products | Tiles, bricks, porcelain |
| Glass products | Flat glass, hollow glass |
| Paper & pulp | Paper, cardboard, pulp |
| Organic raw materials | Ammonia, methanol |
| Other iron/steel/aluminum products | Processed products (e.g., machine components, vehicles, structures) |
Conclusion:
CBAM registration is mandatory when trading in iron, steel, aluminum, cement, fertilizers, hydrogen, or electricity. If you import products from industries such as chemicals, glass, ceramics, plastics, or paper, you will most likely be affected from 2026 onwards and should start preparing now.
Note for SAP users:
Many of these products can already be efficiently managed and tracked in SAP transport logistics systems and via SAP Transportation Management.
What exactly will change as a result of the omnibus initiative on CBAM?
With the so-called Omnibus Package, the EU is responding to criticism from the field and aims to make the CBAM process (Carbon Border Adjustment Mechanism) more targeted and implementable. Some points have already been legally confirmed, while others are still in the legislative process.
What has already been decided (as of May 2025):
- 50-ton threshold (de minimis rule):
- Companies that import less than 50 tons of CBAM-relevant goods per year will be exempt from CBAM reporting in the future. This limit has been confirmed by the EU Parliament and affects around 90% of companies without losing sight of the majority of CO₂ emissions.
- Start of certificate requirement postponed:
- The obligation to purchase CBAM certificates, originally planned for January 2026, has been postponed to February 2027. The reporting requirement remains unaffected.
Still under negotiation:
- Expansion of CBAM product groups:There are plans to expand the scope to include other sectors such as chemicals, plastics, glass, ceramics, paper, and pulp, probably starting in 2026 and gradually expanding until 2030. A final decision has not yet been made.
- Simplification of CBAM reporting: There are discussions about postponing the deadline for the annual CBAM declaration from May to October. A reduction in the mandatory reporting share of emissions from 80% to 50% is also under discussion.
- Default values instead of emissions data: From 2026, country-specific average emissions values will be available for use if no specific data is available. However, these “default values” would be financially less attractive than actual values and would therefore provide an incentive for accurate data collection.