What Is CBAM? Its 2026 Launch, 2027 Certificate Sales and Impacts on Taiwanese Businesses
EU CBAM entered its definitive phase on 1 January 2026. Certificates go on sale on 1 February 2027, with the first declaration and surrender due by 30 September 2027. A guide to covered products, the 50-tonne threshold, certificate prices and preparation for Taiwanese exporters.
What to decide after reading If you came for emission factors, ISO 14064, CBAM, or carbon data, the next step is to check whether activity data, emission factor versions, and supporting evidence can be traced.
Table of Contents
- Sustaihub Key Takeaways
- What Is CBAM? Understanding the EU Carbon Border Adjustment Mechanism
- CBAM's Impact on Taiwanese Companies
- CBAM Simplification Legislation Adopted: Thresholds, Timeline and Certificates
- Strategies for Responding to CBAM
- Digital Tools to Strengthen Carbon Inventories and Respond Quickly to CBAM
Sustaihub Key Takeaways
- When regulated products such as iron and steel, aluminium, cement, fertilisers, electricity and hydrogen are imported into the EU, importers subject to the obligations must declare embedded emissions and purchase CBAM certificates; imports from 2026 onwards are already subject to certificate obligations.
- Importers whose combined net imports of iron and steel, aluminium, cement and fertilisers in a calendar year do not exceed 50 tonnes are exempt from annual declaration, authorisation and certificate purchase obligations, but must still declare this in customs declarations. The threshold does not apply to electricity or hydrogen; if cumulative imports exceed 50 tonnes during the year, all regulated imports become subject to the obligations.
- Certificates for 2026 imports are priced using the quarterly average EU ETS auction price, switching to weekly averages from 2027. From 2027, authorised declarants must hold certificates at each quarter-end covering at least 50% of embedded emissions in cumulative imports for that year.
- Where embedded emissions are calculated using actual emissions, a reduction in the number of certificates to surrender may be requested for carbon prices effectively paid in a third country; payment evidence and other supporting documents must be retained.
Sustaihub's analysis of 49 TWSE/TPEx-listed companies in the iron and steel industry for the 2025 reporting year in the Sustaihub sustainability report database shows that 63.3% list third-party verification or assurance in their sustainability reports (“list” means the verification or assurance provider field in the filed data is populated; it does not mean the assurance covers the entire report). Cross-referenced with 2025 ESG information disclosure open data from the Taiwan Stock Exchange (TWSE, 證交所) and Taipei Exchange (TPEx, 櫃買中心), 79.6% have disclosed Scope 3 emissions. Steel companies exporting to the EU can use these figures to compare the disclosure and verification status of peers' carbon data.
The EU Carbon Border Adjustment Mechanism (CBAM) moved from its transitional to its definitive phase on 1 January 2026. When regulated products such as iron and steel, aluminium, cement, fertilisers, electricity and hydrogen enter the EU, importers subject to the obligations must declare embedded emissions and purchase CBAM certificates. The simplification legislation adopted in 2025, Regulation (EU) 2025/2083, postponed certificate sales to 1 February 2027 and exempts importers whose combined annual net imports of iron and steel, aluminium, cement and fertilisers do not exceed 50 tonnes. The threshold does not apply to electricity or hydrogen. This article explains the latest timeline, thresholds and steps Taiwanese companies can take now.
Turn this article into your next step
If this article touches disclosure, carbon inventory, or report preparation, use the system or database to check how peers handle it.
What Is CBAM? Understanding the EU Carbon Border Adjustment Mechanism
CBAM (Carbon Border Adjustment Mechanism) is an EU policy supporting global emissions reduction goals by imposing additional carbon charges on high-emitting imported products, ensuring EU and foreign businesses compete under equivalent carbon pricing standards and preventing carbon leakage.
CBAM primarily targets carbon-intensive industries including iron and steel, cement, aluminium, electricity, fertilisers and hydrogen. Companies must calculate and report emissions from product manufacturing, while importers must purchase CBAM certificates to cover carbon costs.
CBAM's Impact on Taiwanese Companies
Direct Cost Pressure on Carbon-Intensive Industries
Taiwanese exporters of steel, cement and aluminium to the EU will be directly affected by CBAM and face additional carbon costs that may weaken competitiveness. EU CBAM standards are also becoming stricter, with more industries expected to be covered.
Greater Demand for Supply Chain Management and Carbon Footprint Transparency
Companies need stronger carbon inventory capabilities and transparent supply chain emissions data to meet EU reporting requirements. The EU may require importers to provide complete carbon footprint reports in future, with non-compliance creating trade barriers.
CBAM Simplification Legislation Adopted: Thresholds, Timeline and Certificates
| Date | Milestone |
|---|---|
| 2023-10-01～2025-12-31 | Transitional phase: Reporting only, with no certificate purchases |
| 2026-01-01 | Definitive phase begins: Covered 2026 imports become subject to certificate obligations |
| 2027-02-01 | Member states begin selling CBAM certificates on the common platform |
| 2027-09-30 | First annual declaration and surrender of certificates covering 2026 imports |
| 30 September each subsequent year | Declare and surrender certificates for the preceding year |
Regulation (EU) 2025/2083 has been formally adopted. The 2026 definitive phase and the start of certificate sales in 2027 are separate milestones. Importers subject to the obligations should begin collecting reporting data from 2026.
50-Tonne Exemption Threshold: If the combined net weight of iron and steel, aluminium, cement and fertilisers imported by the same importer in a calendar year is no more than 50 tonnes, including exactly 50 tonnes, the importer is exempt from annual CBAM declarations, authorisation and certificate purchase obligations, but must still declare the exemption in customs declarations. Electricity and hydrogen are excluded from this threshold. If cumulative imports exceed 50 tonnes during the year, all regulated imports for that year become subject to the obligations.
Certificate Pricing and Holding Requirements: Certificates covering 2026 imports are priced using the quarterly average EU ETS auction price for the quarter of importation. Weekly averages apply from 2027. From 2027, authorised CBAM declarants must hold certificates at each quarter-end covering at least 50% of embedded emissions in cumulative imports for that year up to that quarter. Calculations may use default values without mark-ups or eligible prior-year declared data for the same product and country of origin, and must account for EU ETS free allocation adjustments. See the European Commission's Certificate Price Explanation and Amendments to Articles 21 and 22 in the Simplification Regulation.
Deductions for Carbon Prices Paid in Third Countries: Under Article 9 of the CBAM Regulation, where embedded emissions are calculated using actual emissions, authorised declarants may request a reduction in the number of CBAM certificates to surrender for carbon prices effectively paid in a third country. Refunds or other compensation must be accounted for, and payment evidence and other supporting documents retained.
Official information: Climate Change Administration, Ministry of Environment: CBAM Response Portal; Ministry of Economic Affairs Green Trade Information: CBAM Portal.
Strategies for Responding to CBAM
CBAM's core purpose is to align the carbon emissions requirements for imported products with EU domestic production standards, preventing competitive advantages arising from carbon cost differences. Companies unable to provide transparent, accurate carbon data will therefore be unable to enter the EU market and may face substantial tariffs or trade restrictions.
Companies can begin with these two actions:
- Strengthen Carbon Inventory Capabilities
The first step is a comprehensive carbon inventory mechanism. This enables prompt responses to customer requests, supports CBAM compliance, enhances corporate reputation and reduces future penalties or additional costs caused by incomplete data. - Reduce Product Carbon Footprints
Gradually invest in low-carbon production technologies, green energy and improved energy efficiency to reduce product emissions intensity and CBAM costs.
For practical guidance, see Five Steps for CBAM Reporting to organise product classification, thresholds, emissions data and annual reports in sequence.
Digital Tools to Strengthen Carbon Inventories and Respond Quickly to CBAM
Carbon inventory data is complex. When using traditional Excel calculations, any error in formulas or emission factors can undermine accuracy and reduce data credibility.
Sustaihub's DCarbon system automatically calculates corporate emissions and uses generative AI to help produce greenhouse gas inventory reports quickly, reducing report production costs by 30% and preparation time by 50%.
Integrating a carbon inventory system with a company's energy management system can also substantially improve carbon management, ensuring timely, accurate data and strengthening monitoring and decision-making. Sustaihub's DCarbon system integrates closely with Far EasTone's EMS to deliver Taiwan's first one-stop solution combining EMS, carbon inventories and generative AI, providing efficient, intelligent carbon management services.
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✔ Six guided steps: Complete an inventory independently, even without prior experience.
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✔ Automated reporting: Produce inventory reports meeting Ministry of Environment and Financial Supervisory Commission requirements
Carbon inventories are both a compliance requirement and an important milestone in sustainable business management. Sustaihub's DCarbon helps you overcome inventory challenges and strengthen competitiveness. Apply now for a 14-day free trial, explore carbon management solutions and get ahead in the decarbonisation era.
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References: Regulation (EU) 2025/2083, European Commission Official CBAM Information.
Updated on 6 October 2026. Key updates: added CBAM's definitive phase, 2027 certificate and reporting timeline, the 50-tonne threshold and pricing rules.
FAQ
View AllWhen does CBAM officially take effect?
CBAM entered its definitive phase on 1 January 2026, and importers subject to the obligations must account for imports from 2026. Certificates go on sale on 1 February 2027. The first annual declaration and surrender of certificates covering 2026 imports must be completed by 30 September 2027.
How does CBAM affect Taiwan's steel industry?
Taiwanese steel exports to the EU are directly affected by CBAM and face additional carbon costs that may weaken competitiveness, as the EU imposes carbon charges on high-emitting imported products.
What changes does the CBAM simplification package introduce?
Regulation (EU) 2025/2083 has been formally adopted. Certificate sales begin on 1 February 2027, and the first annual declaration and surrender deadline is 30 September 2027. Where the combined net weight of iron and steel, aluminium, cement and fertilisers imported by the same importer in a calendar year does not exceed 50 tonnes, including exactly 50 tonnes, annual CBAM declarations, authorisation and certificate purchases are waived, but the exemption must still be declared to customs. Electricity and hydrogen are excluded. If cumulative imports exceed 50 tonnes, all regulated imports for that year become subject to the obligations.
Turn Carbon Data into an Auditable Workflow
Use DCarbon to calculate emissions with the emission factors you configure and organize activity data and supporting evidence, so inventory data stays traceable, reviewable, and ready for customer requests.
How to decide the next stepTurn the regulation or factor requirements in the article into a data checklist first. If data crosses sites or departments, or needs verification, then evaluate whether system-based management is needed.