The EU Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase on January 1, 2026. Whether a fertilizer is covered depends on its applicable product code, while importers, producers and verifiers carry different data responsibilities.
Three key points about the definitive phase
CBAM currently covers selected goods in six sectors: cement, iron and steel, aluminum, fertilizers, electricity and hydrogen. EU importers or their indirect customs representatives importing CBAM goods above the unified mass threshold need to apply for authorized CBAM declarant status. Coverage of specific goods must still be assessed by product code, origin and applicable rules.
The direct CBAM declarant is usually on the EU side, while producer data enter the importer's compliance chain. Importers may request installation information, production routes, direct and indirect emissions, calculation methods and third-party verification results from Chinese suppliers.
Certificate prices and cash-flow planning
CBAM certificates use quarterly prices in 2026. The European Commission published EUR 75.36 per tonne of CO2 for the first quarter and EUR 75.28 for the second. The price is linked to EU Emissions Trading System auction prices, so one quarter does not represent later quarters.
The formal declaration follows importation, while emissions-data collection, review and contractual arrangements precede it. Importers may specify data deadlines, liability for errors, verification costs and certificate-cost allocation in contracts. Product price, logistics charges, emissions-accounting costs and potential certificate costs are separate items.
The fertilizer supply chain's data chain
Check CN/HS codes, origin and whether the goods fall within fertilizer-related coverage.
Record the installation, raw materials, processes and emissions boundaries.
Prepare default or actual emissions values and supporting calculations under the rules.
Actual values require accredited verification and must be passed to the authorized declarant.
When actual emissions values are used, third-country producers must provide verified emissions data. The European Commission published guidance on verification and accreditation on August 24. From September, accredited verifiers can register in the CBAM Registry. Actual-value files must identify data responsibilities, calculation boundaries, submission timing and record-keeping; a supplier statement alone is not a verification result recognized under the rules.
Compliance files generally cover the production installation, process route, emissions sources included in the calculation, data-review responsibility and revision notices. When the same product comes from plants with different energy mixes, one installation's emissions factor cannot be applied to every batch.
Contract data clauses may specify product codes, the importing entity, data formats, submission frequency, verification responsibility and confidentiality arrangements, while preserving links among batches, quantities and installation data for the importer's annual aggregation.
Upcoming implementation milestones
Authorized declarations, embedded-emissions records and certificate obligations enter the definitive implementation framework.
Accredited verifiers can register in the CBAM Registry and begin verification work, including document reviews and site visits.
Certificates corresponding to 2026 imports will be purchased under the subsequent platform arrangements.
The first declaration covers embedded emissions in goods imported in 2026.
