CBAM 2026 compliance: Will your imports clear EU customs?

CBAM Definitive Phase: Why 2026 is a turning point

The definitive implementation phase of CBAM began on 1 January 2026, replacing the Transitional Phase with stricter legal and operational requirements.

From this point forward, only registered and compliant importers can continue importing CBAM covered goods into the EU. National customs authorities will increasingly rely on the central CBAM register as enforcement tightens.

You can read the official EU guidance on CBAM implementation via the European Commission’s CBAM page, a trusted external source for regulatory updates.

Authorised Declarant status: A critical deadline

By the end of March 2026, all CBAM obligated companies must be registered as Authorised Declarants.

Without this status:

• Imports of CBAM goods can be blocked at customs
• Shipments may be delayed or stopped entirely
• Supply chains face disruption and contractual risk

In practice, this is already happening in some EU countries. Registration is not a simple tick box exercise. It requires detailed company information, supply chain mapping, and emissions data, all submitted through the CBAM portal.

Early submission is not just advisable. It is essential.

TARIC Codes importers must declare

Customs declarations must include the correct TARIC code depending on your CBAM status. The three key codes are:

• Y128 – CBAM Authorised Declarant status granted
• Y238 – CBAM Authorised Declarant application submitted
• Y137 – De minimis exemption under 50 tonnes

Using the wrong code, or failing to register in time, can result in shipments being held at the border. This is where compliance and operational risk collide.

CBAM cost forecasting: Why 2026 data shapes future costs

CBAM certificates will not be available for purchase until 2027. However, the emissions data submitted during 2026 will directly influence your future CBAM cost exposure.

That makes 2026 the year where cost trajectories are set.

Key challenges affecting CBAM costs

• Verification requirements
  Many suppliers provided primary emissions data during the Transitional Phase, but few currently hold the certifications needed for the definitive phase.
• Supplier data gaps
  Where verified supplier data is unavailable, importers must rely on default values, which can significantly increase CBAM liabilities.
• New CBAM benchmarks
  Recently published benchmarks align CBAM more closely with the EU ETS, but also introduce greater complexity into emissions calculations.

Without clear forecasting and supplier engagement, CBAM costs can escalate quickly and unexpectedly.

For further technical detail, the EU’s published CBAM benchmarks and ETS alignment documents provide useful context from an authoritative source.

How Valpak supports CBAM compliance

Valpak supports CBAM obligated businesses across every stage of compliance.

Our services include:

• Authorised Declarant submissions, ensuring accuracy, completeness, and on time approval
• CBAM cost forecasting, using supplier data and purchase orders to model financial exposure
• Supplier engagement, collecting reliable emissions data through our online survey tools
• Data pre verification, preparing emissions data for third party verification audits

You can explore our full CBAM compliance support services through our dedicated web page.

Key takeaways and next steps

CBAM compliance in 2026 is not just about reporting. It affects customs clearance, supplier relationships, and future cost exposure.

To stay compliant and in control:

• Apply for Authorised Declarant status early
• Ensure correct TARIC codes are used
• Engage suppliers now to secure verified emissions data
• Forecast CBAM costs before liabilities crystalise

Visit our CBAM web page to understand how Valpak can support your UK and EU CBAM compliance.
Enquire about our UK and EU CBAM Compliance Support Services to reduce risk and protect your supply chain.
Take our EU CBAM Obligation Quiz to confirm whether your business is obligated.
UK CBAM Obligation Quiz coming soon!