As of December 31, 2025, the transition period of the EU Carbon Border Adjustment Mechanism (CBAM) will officially conclude, and the full carbon tariff collection phase will kick off in January 2026. 6 key industries must prioritize compliance: steel, aluminum, cement, fertilizers, electricity, and hydrogen. Currently, chemicals and plastics have been included in the evaluation framework and may be brought under regulatory scope in the future. Failure to complete compliance preparations in a timely manner will not only lead to EU market access barriers but also result in direct financial losses for enterprises.
I. From Reporting to Taxation: Core Changes in 2026
The transition period centered on "reporting," while the official implementation phase will shift to "tax payment + compliance fulfillment." The key differences are summarized as follows:
Transition Period (Oct 2023 - Dec 2025)
● Core Requirement: Quarterly carbon emission reports (no tax payment)
● Responsibility Nature: Information disclosure obligation only
● Verification Requirement: Voluntary verification
● Penalty Mechanism: Report return for revision
Official Implementation Phase (Jan 2026 onwards)
● Core Requirement: Submit CBAM certificates + pay carbon tariffs (phased reduction of free allowances)
● Responsibility Nature: Both information disclosure and tariff compliance
● Verification Requirement: Mandatory third-party verification
● Penalty Mechanism: Fines + EU market access ban
Additionally, the EU "Simplification Proposal" clearly stipulates that for imported goods in 2026, enterprises must still submit CBAM certificates as required, but the purchase of certificates can be delayed until February 2027. Carbon prices will be calculated based on the average price of EU Emissions Trading System (EU ETS) allowances in 2026. This measure provides enterprises with more time to establish systems for tracking, verifying, and pricing embodied carbon in the supply chain.
II. Seize the Last Opportunity: Final Reporting Drill in the Transition Period
According to CBAM transition period regulations, authorized declarants (including EU importers and indirect customs representatives) must submit CBAM reports within 1 month after the end of each quarter. Notably, reports are not final: revisions are permitted within 2 months of each quarter’s end.
A final reminder: The period from October to December 2025 is the last reporting cycle of the transition period. The corresponding submission deadline is January 31, 2026, and the revision deadline is February 28, 2026. Enterprises are advised to plan in advance to avoid missing this critical drill and revision window.
If you encounter any issues during the reporting process, feel free to consult us at SKYCO2. As an experienced team specializing in CBAM compliance services, we not only provide policy interpretation and data accounting guidance but also help you efficiently resolve reporting challenges, ensuring peace of mind before the deadlines.