EURANIMI Calls for Extension of CBAM Declaration Deadline

Aligning the 2027 CBAM Declaration Timeline with Market Reality.

Even before entering its financial phase in 2026, the Carbon Border Adjustment Mechanism (CBAM) raised practical implementation concerns. Under CBAM rules, importers must declare the embedded emissions for their 2026 imports by 30 September 2027 at the latest.

CBAM certificates must be surrendered to cover all eligible imports. Embedded emissions are calculated based on actual emissions generated during production and/or processing during the 2026 calendar year (1 January – 31 December 2026).

So far, so good.

In practice, however, this means emissions at non-EU installations can only be verified as of January 2027 onward. A structural constraint that means installations across all six CBAM sectors worldwide will be seeking verification in a very short window of time.

However, the global pool of accredited verifiers – and their available personnel -is limited. Physical on-site verification is required for the initial certification. This is not a simple administrative formality but a full technical audit.

The constraint is purely operational: it is impossible to verify all relevant installations worldwide in the space of eight to nine months. Without official verification, default CBAM values (which often far exceed actual emissions) will be applied.

Against this background, EURANIMI calls on the Commission to submit, for approval by the Parliament and the Council, a proposal that allows installations worldwide to use the full year 2027 — rather than only the first nine months — to obtain verification and validation of their emissions data.

The Challenge of Verified Emissions Data

Both CBAM’s design and importers’ economic interests point towards the use of actual emissions data. But to declare actual emissions, the data concerned must first be verified and validated.

The availability of such verified data — and therefore the ability to benefit from lower carbon costs when sourcing from low-emission producers — depends on factors entirely outside the importer’s control:

1. Verification of emissions data from the production site, and
2. Verification of emissions embedded in the input materials used in the production of the goods.

Where verified data is not available, economically punitive default values must be applied. Crucially, importers will only know in the course of 2027 — often not before its second half — whether their suppliers’ emissions have been verified in time to declare actual emissions.

This creates a prolonged period of uncertainty affecting planning, financing, and competitive positioning and weakens the carbon price signal during the initial implementation phase.

Financial and Commercial Uncertainty

Contracts supplying the EU manufacturing industry in 2026 — and to a large extent also in 2027 — will be negotiated and priced under a fundamental uncertainty: whether actual emissions can ultimately form the basis of the CBAM financial adjustment (the mechanism’s stated objective) rather than default values that override the benefits of low-emission sourcing.

This leaves SMEs caught between two risky pricing strategies:

Option 1: Price goods based on manufacturer-reported emissions and internal assessments, allowing the benefit of sourcing from low-emission producers and resulting in an expected CBAM cost in the range of €0-100 per tonne, depending on the product category. However, if verification cannot be completed in time — for reasons linked to capacity and scheduling constraints across verifiers — default emission values apply and additional CBAM certificates must be surrendered, potentially driving the CBAM cost to €600-800 per tonne irrespective of the supplier’s actual performance.

Option 2: Price conservatively using default values. This may, however, lead to significant over-pricing compared to competitors who still ignore or underestimate their future liability.

Emerging Market Distortion

Unsurprisingly, this impossible dilemma creates a structurally unstable market, and distortions are already beginning to emerge:

• Prudent firms are penalised, while risk‑takers may accrue hidden liabilities.
• Competition is driven by speculation or risk-taking rather than genuine carbon performance.
• The original purpose of CBAM – aligning carbon costs – becomes blurred.

For many SMEs, CBAM thus becomes not only a compliance obligation but a strategic pricing risk unrelated to environmental performance.

Extending the Deadline: a win‑win

The Commission has already recognised practical constraints by postponing the first annual declaration deadline from end‑May to end‑September 2027 in Regulation 2025/2083.

We propose a further extension to 31 December 2027: a focused adjustment that respects the fiscal year, improves the environmental effectiveness of CBAM, and provides the certainty needed for a healthy, competitive steel and aluminium market.

1. More real‑emissions assessments – An extra three months gives verification bodies time to certify more installations worldwide, reducing reliance on economically punitive default values.
2. Stronger environmental logic – Importers are encouraged to favour genuinely low-emission suppliers rather than hedging against worst‑case defaults.
3. Reduced market distortion – Prices better reflect actual carbon intensity rather than uncertainty margins.
4. Lower financial shock risk – Smoother cash‑flow for SMEs, avoiding sudden 2027 adjustments that could threaten business continuity.
5. Legal certainty – Both economic operators and customs authorities benefit from clearer, more practical timelines.

Preserving CBAM’s Credibility

Crucially, such an extension does not dilute CBAM’s objectives. On the contrary, it aligns the declaration timeline with the realistic pace of global verification, preserving the mechanism’s integrity and purpose while enhancing its credibility.