On January 1, 2026, the EU Carbon Border Adjustment Mechanism (CBAM) will officially enter the full mandatory implementation phase.
On December 17, the European Commission released 24 supporting detailed documents covering the entire process of emission calculation, customs declaration, certificate pricing, and verification execution, marking the complete shift of this "carbon tariff" policy from framework to practical implementation.
Its scope is set to expand from 6 upstream industries to 180 downstream products, covering machinery, vehicle components, household appliances, construction equipment and other fields, and global enterprises exporting to the EU have entered the final sprint stage of compliance preparation.

1. Expanded Coverage, Downstream Enterprises Fully Included
Previously, only 6 carbon-intensive upstream industries such as steel, cement, and aluminum were regulated during the transition period. The new regulations add 180 downstream products, which is expected to bring about 7,500 new global importers under the obligation of declaration.
This means that not only upstream raw material enterprises need to comply, but also downstream manufacturing enterprises relying on relevant materials will be included in supervision, achieving full-scale extension of compliance boundaries.

2. Upgraded Accounting Rules, Cost Surge Due to Lack of Data
The EU explicitly includes pre-consumer aluminum and steel scrap in carbon emission accounting, and additional proof is required if data is unreliable.
The accounting formula has been clarified: CBAM Cost = (Total Embedded Emissions - Free Allocations) × Certificate Price - Carbon Price Paid in Third Countries.
Enterprises that fail to provide verified actual emission data must apply EU default values higher than the industry average, coupled with annual punitive markups (10% in 2026, 20% in 2027, and 30% from 2028 onward, capped at 1% for the fertilizer industry), directly driving up export costs.

3. Rigid Verification Requirements, Actual Data is Key
Declaration using actual emission data requires third-party verification recognized by the EU: on-site verification is mandatory in the first year, and remote verification is allowed from the second year if 6 major conditions are met, but at least one on-site inspection is required annually.
Verification focuses on production boundaries and data allocation. Enterprises must prepare complete production accounts, energy consumption records and other materials; otherwise, high default values will be imposed compulsorily.

1.Difficulty in Scope Definition: The 180 new downstream products have complex classifications, making it easy to miss declarations or make misdeclarations due to incorrect categorization;
2.Difficulty in Data Traceability: It is challenging to collaboratively collect data across the entire supply chain. Small and medium-sized enterprises lack mature systems, facing the dilemma of "building a system or bearing high default values";
3.Difficulty in Verification Preparation: Resources of EU-recognized verification institutions are tight. If enterprises delay cooperation, they may miss the compliance deadline.

1.Precise Alignment: Cross-reference the CBAM product list and new classifications to clarify product regulatory attributes and own compliance obligations;
2.Establish Data Systems: Build a full-process carbon emission traceability mechanism for production, connect with upstream suppliers to obtain raw material data, and reduce reliance on default values;
3.Advance Verification: Engage with EU-recognized third-party verification institutions as early as possible, sort out material lists, and establish standardized carbon management processes.

Faced with CBAM's refined requirements, enterprises advancing independently are prone to problems such as deviations in rule interpretation and non-standard data accounting.
Based on in-depth interpretation of EU carbon policies and global compliance experience, SKYCO2 provides end-to-end support:
• Compliance Alignment: Decode 24 detailed documents to clarify enterprises' compliance boundaries and obligations;
• Data Accounting: Guide the establishment of EU-standard actual data systems and accurately calculate carbon costs;
• Verification Support: Connect with EU-recognized verification institutions, sort out materials, simulate processes, and ensure smooth verification;
The implementation of CBAM marks the arrival of the "carbon compliance" era in global trade. Compliance is both a threshold and an opportunity for low-carbon transformation.
If you are worried about CBAM scope definition, data accounting, or verification preparation, please feel free to contact SKYCO2. Let professional services help your enterprise calmly respond to challenges and seize competitive advantages in global green trade.