CBAM Definitive Phase: Exactly What Changes for Indian Exporters on 1 January 2026

From 1 January 2026, CBAM moves from reporting-only (transitional phase, October 2023 to December 2025) to full operation. EU importers of covered goods must now purchase and surrender CBAM certificates — not just submit emissions reports.

What changes on 1 January 2026: (1) EU importers must purchase CBAM certificates from the EU CBAM Registry at a price linked to the weekly EU ETS auction price (approximately EUR 65-70/tonne CO2 as of early 2026); (2) Certificates equal to the embedded CO2 emissions in imported goods must be surrendered by 31 May of each year for the previous year' imports; (3) CBAM declarants (EU importers) must be authorised by their national CBAM authority before importing.

What Indian exporters must do: (1) Provide EU importer with embedded emissions data per tonne of product; (2) Arrange third-party verification if required; (3) Address CBAM cost allocation in export contracts — who pays for CBAM certificates, Indian exporter (via lower price) or EU importer (directly)? (4) Invest in decarbonisation — every tonne of CO2 eliminated at source saves approximately EUR 65 in CBAM at current prices.

Use AJG' CBAM Calculator at tools/cbam-calculator.php to model your specific CBAM liability.