The CBAM directly impacts companies that import products belonging to the sectors included in the mechanism: iron and steel, aluminum, cement, fertilizers, hydrogen and electricity. These sectors concentrate significant emissions and are fully incorporated into the regulatory scope of the CBAM as of 2026.

The mechanism obliges only authorized CBAM declarants to import such goods, whether they are importers established in the EU or indirect customs representatives who assume the obligations arising from the mechanism.

Implications for companies

For industrial companies, the entry into force of the CBAM implies:

• Cost increases in emission-intensive products, with estimated impacts of 7-8 % and peaks of 20 % in manufactured goods, especially in automotive and metallurgy.

• Obligation to collect accurate data on actual emissions or default values for each imported good.

• Review of contracts and processes with suppliers, who must provide verifiable emissions information.

• Adjustments in economic planning, incorporating the purchase of certificates as a new regulatory cost.

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New 50-ton threshold and scope of obligation

The Regulation introduces a single mass-based threshold of 50 tons per year per importer per year.

Whoever exceeds this volume in the CBAM sectors is fully subject to the mechanism and must request authorization, file declarations and acquire certificates.

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What companies must do before 2026

To ensure the continuity of their operations, companies must:

Obtain CBAM authorized declarant status. The application is made exclusively through the European CBAM Registry, and requires:

• Valid EORI number.
• Certificate of updated tax situation.
• Import estimates by type of merchandise.
• Affidavits.
• For companies with less than two years of activity, a mandatory financial guarantee.

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Applications submitted before March 31, 2026 allow for provisional imports to continue until resolution.

Prepare for emissions calculation and reporting.

From 2026 onwards, emissions will be calculated using verified actual values or default values developed by the European Commission. The first annual declaration shall be submitted by September 30, 2027 for 2026 imports.

Plan the purchase of certificates.

The quarterly obligation will be to dispose of 50% of the certificates corresponding to the accumulated emissions since the beginning of the year. The delivery of certificates will begin in 2027.

amec’s role in this process

amec is a member of the Industry and Ecological Transition Commission, as well as of the CC. GT Climate Change and CC. GT Industry, spaces in which regulatory developments, sectoral impacts and adaptation needs of industrial companies are analyzed.

The association is working to anticipate the effects of CBAM, convey the industry’s concerns and strengthen companies’ preparedness for this new regulatory framework.