What the leaked CBAM drafts could mean for importers in 2026


Carbon Footprint

Are you prepared for the potential impact of the leaked CBAM drafts on your imports in 2026?

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.

Country and installation specific benchmarks

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

Verification rules may align with EU ETS

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.

Materiality threshold to increase accuracy

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.

Bottom line

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.

ichael Trotter Comas

Written by: Michael Trotter Comas

Topics:

Blog, CBAM, CBAM Compliance Understanding Your Obligations

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