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What's inside:
- 6 action areas covering supply chain, deadlines, and cost exposure
- The 5 steps to cut CBAM liability by 50–70% with verified data
- A deadline tracker for certificate purchases and declarations
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Your CBAM 2026 Compliance Checklist
Thanks — here's your checklist. Work through each section in order; items build on each other.
1. Understand Your Exposure
Confirm whether you import raw aluminium or export anodised components to the EU.
Both directions carry CBAM obligations — importers pay for embedded carbon; EU customers will ask exporters for verified emissions data.
Check the 50-tonne annual import exemption.
If you're under the threshold you're temporarily exempt — but confirm your EU customers won't still require emissions data.
2. Audit Your Supply Chain
Identify the origin and carbon intensity of every aluminium supplier.
Carbon intensity ranges 4–20 kg CO₂e/kg depending on smelting method — a 5x swing that goes straight into your CBAM bill.
Request verified emissions data from suppliers instead of accepting default values.
Verified data vs. penalty defaults can cut CBAM liability by 50–70%.
Shortlist low-carbon (renewable/hydro-powered) suppliers for future sourcing.
3. Track the Critical Deadlines
Feb 1, 2027 — first CBAM certificate sales begin.
Quarterly — hold certificates equal to 50% of year-to-date embedded emissions.
Sep 30, 2027 — first annual CBAM declaration deadline, covering 2026 imports.
4. Model the Cost Impact
Calculate your exposure at today's certificate price (€70–100/tonne CO₂).
The CBAM factor rises from 2.5% of emissions charged in 2026 to 100% by 2034 — model both ends.
Compare default-value cost vs. verified-data cost for your top suppliers.
Use our ROI calculator to see the combined energy + compliance savings case.
5. Put Systems in Place
Replace manual spreadsheet tracking with automated carbon monitoring.
Manual tracking across shipments and suppliers is slow and error-prone at CBAM's reporting cadence.
Set up quarterly reporting aligned to EU methodology, not just annual.
6. Prepare for What's Next
Watch for CBAM scope expansion to downstream/finished products.
Proposed December 2025 — could bring finished anodised components under CBAM directly, not just raw aluminium.
Explore eligibility for EU decarbonisation funding.
25% of 2026–27 CBAM revenue supports industry decarbonisation projects.
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