Recent reports from trusted sources including S&P Global, Carbon-Pulse, Argus, and Carboneer suggest that the European Commission may significantly tighten verification rules for CBAM ahead of its full implementation next year. While the drafts are not yet officially published, early insights indicate important implications for importers.
The leaked CBAM drafts point to a shift from broad product averages to country- and installation-specific carbon intensity benchmarks.
Key takeaways:
Production processes and installation location will influence compliance costs
Similar products from different installations may have different CBAM obligations
Implications:
Importers may prefer fully verified, low-emission installations over lower-cost suppliers
Cleaner producers could gain a competitive advantage under stricter verification rules
Reports indicate that the draft verification rules mirror elements of the EU Emissions Trading System (ETS), including:
Annual verification cycles
Accredited verifiers
Physical and virtual installation visits
Harmonised calculation methodologies
Implications:
Importers may face ETS-level scrutiny even for non-EU suppliers.
Reliance on low-transparency installations could increase compliance risk.
Leaked drafts suggest a potential materiality threshold of around 5%, below which minor discrepancies may be tolerated.
Implications:
Encourages precise emissions measurement and reporting.
Reduces disputes during audits.
Makes accurate primary data reporting essential for compliance.
The leaked CBAM drafts point to stricter verification, aligned with EU ETS standards, turning CBAM compliance into a supply chain due-diligence challenge. Importers should expect:
Higher administrative costs
Reduced sourcing flexibility
Competitive advantage for well-documented, low-emission suppliers
While the draft still awaits formal adoption, early preparation will help companies minimise disruption in 2026.
Read about officially announced CBAM simplifications here.
Want to ensure your business is ready? Visit our CBAM Compliance services page to learn how we can support your import operations.
