What is the Carbon Border Adjustment Mechanism (CBAM)?
The Carbon Border Adjustment Mechanism (CBAM) is an EU instrument designed to create a level playing field in climate protection. When particularly emission-intensive goods such as iron, steel, cement, aluminum, fertilizers, electricity, and certain intermediate and end products are imported from third countries, CBAM ensures that these imports bear a comparable CO₂ price to goods produced in the EU.
The CBAM obligations cover all products of CN positions 7301-7311, 7318, and 7326 - including screws, nuts, rivets, and other fasteners.
The mechanism is based on the EU Emissions Trading System (EU ETS) - the European market where greenhouse gas emissions are priced. Importing companies will have to purchase CBAM certificates in the future, the price of which is based on the EU ETS.
From 2026, CBAM goods may only be imported by approved CBAM declarants. Lederer GmbH has, of course, qualified early for this status and received the corresponding approval from the Federal Environment Agency.
Lederer as a Pioneer in the Transition Phase
Since the beginning of the transition phase on October 1, 2023, Lederer GmbH has been working intensively on the implementation of CBAM. We involved our suppliers early on and were able to report a large part of our imports with actual data provided by the suppliers during the transition phase. This pioneering work has helped us to establish CBAM-oriented processes early on and build trust with our partners.
New Requirements from 01.01.2026
The CBAM regular phase brings some important innovations, which we summarize for you be-low:
1. Transition to Regular Phase
The transition phase (Oct. 2023 - Dec. 2025) was intended to learn about emissions and to report quarterly. The regular phase begins on January 1, 2026, with an annual CBAM declaration and the first certificate purchase.
2. Approved CBAM declarant
From 2026, CBAM goods may only be imported by companies that have the status of an approved CBAM declarant.
3. Purchase and Submission of Certificates
The number of CBAM certificates to be purchased is based on the reported emissions. The sale of certificates starts in 2027; the certificates for imports from 2026 must then be purchased retroactively for the year 2026 in 2027. The pricing of CO₂ emissions is therefore already effectively underway!
4. Emission data and Verification
The emissions data to be reported can be based on default values from the EU Commission or on actual data from the manufacturers. The default values cause significantly higher costs than actual data. However, actual data can only be used if it has been verified by an accredited verifier. The EU is currently working on the accreditation of these verification organizations. It is currently expected that they will start their work in Q4 2026. However, it is currently difficult for us to estimate when our suppliers in Asia will actually be verified.
Dealing with Open Questions
Many detailed regulations - e.g., on data verification, actual values for intermediate products, and the expansion of the product scope from 2028 - are currently being finalized by the EU. However, we are working intensively with our suppliers to prepare for the upcoming requirements and are in constant contact with them to optimize data collection and prepare them for the verification process.
Do you have questions about CBAM? Our CBAM officer Hanna Dudel-Wiese will be happy to assist you: hdudelwiese@lederer-online.com .
Contact us - together we will shape a more sustainable future.
