CBAM: a summary of two years and new obligations from 2026

October 2025 marked two years since the launch of CBAM, and in just a few weeks the mechanism will enter its target phase. From January 1, 2026, every import of regulated goods will involve a real cost, the need to account for the emissions embedded in the imported products. What does the two-year transition period show, and what challenges will importers face in 2026? Szymon Lipiński, Senior Tax Consultant at Crowe Poland, analyzes the key conclusions and directions of change that may shape the future of the mechanism.

For the first two years after the launch of CBAM in October 2023, the key requirement was quarterly reporting of the weight of imported goods, with the option of using default emission values. According to European Commission data, initially almost all importers took advantage of these simplifications, limiting themselves to customs data. However, in subsequent stages, the EU legislator opted for mobilization, requiring the reporting of actual embedded emission values. This step required companies to conduct in-depth analysis and cooperate with foreign suppliers, which was intended to prepare the market for the tough conditions of the target phase.

At present, the European Commission is working on seven (!) implementing and delegated acts and an amendment to the CBAM regulations. It is therefore difficult to clearly indicate what rules will govern the CBAM target period. However, the CBAM Regulation of 2023 provides some guidance - explains Szymon Lipiński, Senior Tax Consultant at Crowe Polska, in an article for the ESGtrends portal.

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This article is available in Polish only.