The Carbon Border Adjustment Mechanism (CBAM) of the European Union is one of the central instruments for promoting sustainable production and transparency of emissions in global supply chains. Since its introduction in October 2023, CBAM has been in a transitional phase that runs until the end of 2025. After the end of the transitional phase and with the start of full CBAM implementation in 2026, certification as a CBAM declarant will also become mandatory – a process that can take up to 180 days and should therefore be started early.

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CBAM and Its Significance for Mid-Sized Companies

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CBAM aims to minimize competitive distortions caused by differing climate protection measures between the EU and other countries. By quantifying and monetizing the CO₂ emissions of imported goods, an incentive is created to make supply chains more sustainable. For companies, however, this means they must increasingly provide detailed information about the emissions of their products and intermediate products – a challenge that requires significant adjustments, especially for smaller and mid-sized companies with limited resources.

Since August 2024, for example, only real data has been permitted for reporting, which increases pressure on companies regarding data quality and verification obligations. From 2026, external certification of this data will be mandatory, as will the purchase and surrender of CBAM certificates.

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Requirements for CBAM Declarants

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To obtain CBAM declarant status, companies must meet specific prerequisites and complete a clearly defined registration process. These include:

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• Detailed information about the company structure: such as EORI number, economic activity in the EU, and financial capacity.
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• Proof of legal and tax integrity: Sworn declarations of compliance over the past five years.
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• Import structure data: Forecasts of import volumes and monetary values.

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The digital submission of these documents is made through an electronic CBAM register, and processing by the responsible national authority can take up to 180 days. Missing documents or insufficient evidence can significantly delay the process or lead to rejection of the application.

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Strategic Preparation: Why Act Now?

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The CBAM transitional phase gives companies the opportunity to gradually adapt their processes. Acting in time minimizes risks such as legal sanctions and operational disruptions. Especially for mid-sized companies, a clear strategy is necessary to meet the growing requirements:

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1. Create transparency:

‍Identify CBAM-relevant products and suppliers, and begin collecting emissions data.

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2. Automate processes:

‍Digital tools such as Supplier Relationship Management (SRM) systems can help standardize and simplify data collection, management, and reporting.

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3. Avoid bottlenecks:

‍Since the processing of the registration process can be lengthy, early submission is recommended.

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Support Through Technology and Partners

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The implementation of CBAM-compliant data management can be facilitated by specialized software solutions. An SRM system like Tacto's offers, for example:

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• Automated queries of emissions data from suppliers
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• Real-time analysis and documentation of the CO₂ footprint at the item level
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• Generation of reports for quarterly reporting and subsequent certification

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Conclusion and Outlook

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CBAM represents a significant challenge for many companies but simultaneously offers the opportunity to future-proof their own supply chains. The transitional period should be used intensively to implement necessary adjustments and apply for declarant status in time. Companies that act now not only secure legal and operational stability but also strengthen their competitive position.

The full application of CBAM from 2026 will be characterized by strict controls and regular adjustments. In the future, additional sectors and products could be included in the scope, making the requirements for companies even more complex. At the same time, innovative technologies and data-driven solutions for supply chain optimization are expected to gain further importance. Companies that act proactively will be in a position to benefit from this development and strengthen their market position.

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Download the detailed guide to derive concrete recommendations for action for your company!

From 2026, certification as a CBAM declarant will be mandatory for all companies importing goods into the EU. Since the registration process can take up to 180 days, an early start is crucial to be ready in time. Companies must provide detailed data on emissions and imports and fulfill strict verification obligations. Those who create transparency now, automate processes, and prepare the registration will minimize risks and secure their competitiveness in the new regulatory environment.