[2026 Update] EU CBAM Enters Its Definitive Phase: How Can Taiwanese Exporters Stay Globally Competitive?

Introduction: Why Companies Cannot Wait at the 2026 Turning Point

Many Taiwanese exporters assume they can relax in 2026 because purchases of CBAM certificates start in 2027. In fact, emissions from imports throughout 2026 form the basis for the first certificates, with the first annual declaration and certificate surrender deadline on September 30, 2027. Inaccurate data or reliance on default values may inflate certificate requirements and result in substantial carbon costs.

Immediate action is therefore essential. Establishing a system for actual emissions data not only ensures compliance but also helps companies optimise pricing and remain competitive in the EU market.

For CBAM fundamentals, covered products and the full timeline, see What Is CBAM? This article focuses on reporting practice in the 2026 definitive phase.

1. The 2026 Changes: From Reporting Only to Paying for Emissions

In the definitive phase, CBAM's core mechanism shifts from quarterly processes to annual settlement, with the following key changes:

• Certificate purchase timeline: February 1, 2027 is the official start of sales. Importers must purchase certificates corresponding to their total emissions from imports in 2026.
• First settlement deadline: The annual report must be submitted and certificates surrendered by September 30, 2027.
• Price linkage: Certificates corresponding to 2026 imports use the quarterly average EU ETS auction price, switching to weekly averages from 2027. Higher emissions therefore place greater financial pressure on exports.

Under this model, obligations accumulate during the year and are settled the following year. Higher emissions require more certificates and increase export costs. Taiwanese companies should collect data early to help EU importers calculate embedded emissions accurately.

2. Moving Beyond Reliance on Defaults: Actual Data Helps Manage Carbon Costs

When default values are used in the definitive phase, the statutory markup must be applied according to the product and year; one percentage cannot be applied to all products. Companies can compare actual process data with the applicable default values to assess cost implications.

1. Default value markups: Under Annex I to Regulation (EU) 2025/2621, as amended by Regulation (EU) 2026/1740, the total-emissions default value fields for cement, iron and steel, aluminium, and hydrogen have markups of 10% in 2026, 20% in 2027 and 30% from 2028 onward. Fertilisers have separate provisions and are not subject to these rates.
2. Advantages of actual values: Using compliant actual emissions verified by accredited verifiers avoids default-value markups for the portion covered by those actual emissions. The cost difference still depends on actual emissions relative to the applicable default values and cannot be treated as a fixed 10% saving.
3. Financial knock-on effects: Relying on default values can make quotations less competitive and drive customers toward competitors with low-carbon data.

3. Carbon Fee Deductions in Practice: Avoiding Unnecessary Costs

As Taiwan prepares to implement carbon fees, exporters often ask: "Can carbon fees already paid locally prevent duplicate CBAM charges?" The answer is yes. The EU provides a deduction mechanism to address double charging, but companies must prove that the carbon price has actually been paid and is directly attributable to the emissions of the declared products.

4. A Practical Guide: Five Steps to Complete CBAM Reporting

Based on the latest Omnibus Regulation (EU) 2025/2083, Taiwanese exporters should take the following steps:

1. Determine the product CN code: Confirm whether products such as cement, iron and steel, aluminium, fertilisers and hydrogen are covered.
2. Assess the 50-tonne mass threshold: This is a welcome recent change. If an EU importer's combined net imports of iron and steel, aluminium, cement and fertilisers within the same calendar year do not exceed 50 metric tonnes, including exactly 50 metric tonnes, it may be exempt from declaration and certificate obligations. Electricity and hydrogen are excluded from this threshold.
3. Compile data and define boundaries: Collect data on on-site processes, energy and upstream emissions. When collecting emissions data inside and outside the facility, remember that the EU has stringent requirements for calculation boundaries and activity data sources. With such limited tolerance for error, small formula discrepancies or batch-entry mistakes in manual Excel workflows can trigger knock-on effects, undermining the credibility of the final declaration and eligibility for cost deductions.
4. Calculate embedded emissions accurately: Monitor and allocate emissions using the latest EU methodology. When combining actual and default values, account for the complexity of weighted calculations.
5. Produce the annual report: Submit it through the CBAM Registry. Final verification of 2026 data will be completed in September 2027

Conclusion: When AI Meets CBAM—From Anxiety to Automated Data Governance

The central challenge in CBAM's definitive phase is data governance. Turning emissions figures into verifiable, traceable assets is essential for survival in the era of green trade.

Traditional Excel workflows struggle with complex audit trails and changing statutory markups. Consider digital tools such as the DCarbon Cloud Carbon Inventory Platform to digitise data compilation, calculations and document generation. Strengthening your data system in 2026 can help avoid cost shocks in 2027 and protect your long-term advantage in the EU market!

Official information: Ministry of Environment Climate Change Administration: CBAM Response Portal; Ministry of Economic Affairs Green Trade Information Network: CBAM Section.

Updated on October 6, 2026. Key updates: further reading on CBAM fundamentals, plus details on default value markups, certificate pricing and the 50-metric-tonne import threshold.

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