CBAM
The Carbon Border Adjustment Mechanism entered its definitive phase in January 2026. Importers of covered goods need authorised declarant status. Certificate sales open 1 February 2027. The first annual declaration and certificate surrender are due by 30 September 2027, for 2026 imports.
Reporting became payment
A financial obligation
The transitional phase asked for reports. The definitive phase asks for certificates surrendered against a declaration, with penalties behind it.
The cost climbs to 2034
A phase-in factor limits the obligation in the early years and rises each reporting year. Planning on the 2026 number understates what is coming.
The small-consignment exit closed
The 150 euro per consignment derogation was repealed by Reg (EU) 2025/2083 and replaced with a single mass-based threshold.
Scope and the threshold
Once cumulative net mass passes 50 tonnes per importer per calendar year, the full annual volume is obligated, not the excess.
Direct emissions only (most CN codes)
Direct emissions only
Direct and indirect emissions
Direct and indirect emissions
Outside Art. 2a, obligated from the first unit
Outside Art. 2a, obligated from the first unit
The threshold sits in Art. 2a of Regulation (EU) 2023/956 as amended. The military-use exclusion under Art. 2(3) remains in force.
The seven-step workflow
Set up the declarant
Authorised declarant, EORI, reporting year and installations of origin.
Load the imports
Goods, CN codes, net mass and country of origin for the year.
Attach supplier data
Actual verified emissions from the installation, with the verifier's report.
Run the obligation
Deterministic engine, twelve steps, each recorded.
Deduct carbon price paid
Carbon price already settled at origin, where it is evidenced.
Review the position
Certificate count, phase-in factor and the basis for every figure.
Export the declaration
XML for the declarant to file, with the supporting pack.
What the engine establishes
The engine takes no view and makes no estimate. Every figure it produces can be traced back to an input and an article.
The calculation
- Whether the importer crosses the mass threshold for the calendar year
- Embedded direct emissions for each good, from the installation's data
- Embedded indirect emissions where the goods group requires them
- The emissions basis for each line: actual verified today, default route in build
- The phase-in factor for the reporting year
- The carbon price paid at origin, deducted where evidenced
- The certificate count to surrender
The record
- Inputs held with their source and the date they were supplied
- Method named for each step, not implied
- Regulatory values loaded from the instrument, never inferred
- Recalculation reproducible and versioned
- Carbon price deduction evidenced or absent, never assumed
- Trail retained for audit by default
Certificates
The certificate price tracks the EU carbon price. For 2026 imports it
is set quarterly. From 2027 it is set weekly. A year's exposure is therefore not fixed at the moment of import.
An importer who prices CBAM once, at the start of the year, is carrying EU
ETS volatility without knowing it.
Clite reports the position as it stands. It does not forecast the carbon price.
Regulations covered
- REGULATION (EU) 2023/956
- The mechanism itself.
- REGULATION (EU) 2025/2083
- Omnibus amendment, including the mass threshold.
- IR 2025/2546
- Verification of embedded emissions.
- IR 2025/2547
- Calculation methodology.
- IR 2025/2548
- Price of CBAM certificates.
- IR 2025/2620
- Free allocation adjustment and CBAM benchmarks.
- IR 2025/2621, AS CORRECTED BY IR 2026/1740
- Default values and mark-up. Route in build.
Operating model
Stated plainly, because the division of labour is where CBAM projects go wrong.
- SUPPLIER CONTACT
- The importer approaches the supplier. Clite works from the documents the supplier furnishes.
- SITE VISITS
- None. Clite provides technology services only.
- FILING
- Clite produces the declaration XML. The declarant submits it.
- REGISTRY
- Integration is out of scope.
- DATA RETENTION
- Audit trail kept by default, deleted only if you opt out.
- HOSTING
- AWS eu-west-1 (Ireland).
Known limits
Published here rather than discovered in a sales call.
Default values
The default values under IR 2025/2621, as corrected by IR 2026/1740, are not yet loaded. The default route and its mark-up are in build.
Schema validation
The official EU XSD has not been released. Output XML is produced for the declarant's workflow but cannot yet be validated against the published schema.
Supplier onboarding
Bringing a non-EU supplier to verified-data readiness is on the roadmap. Today the platform serves suppliers already reporting actual verified emissions.
Onboarding checklist
Confirm authorised CBAM declarant status and the EORI the imports sit under.
List goods, CN codes and expected annual net mass, so the threshold test can be run early.
Identify the installation of origin behind each good and the operator who runs it.
Request actual verified emissions and the accredited verifier's report from each installation.
Gather evidence of any carbon price already settled at origin. Without evidence there is no deduction.
Load the year, review the position line by line, export the declaration and submit it.
On the horizon
UK CBAM
A second jurisdiction, from 1 January 2027, will be handled as a parameter set on the same module rather than a separate build.
Downstream goods
The proposed 2028 extension to downstream goods is the largest change on the horizon. The module is architected for it.
CBAM is the first of five mandates on a single base. See the full ledger.
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