CBAM in a new scope – changes in imports to the EU

Szymon Lipiński, Senior Tax Consultant, Crowe Poland

The EU's Carbon Border Adjustment Mechanism (CBAM) is entering its next phase. The European Commission has proposed changes that significantly expand the scope of the regulations and cover a growing number of companies operating in international supply chains.

For companies importing goods into the European Union, this means not only new reporting obligations, but also a potential increase in operating costs and the need to incorporate CBAM into strategic, tax and ESG decisions.

We explain below:

what is changing,
to whom does the new regulations apply,
how to prepare your company for upcoming responsibilities.

CBAM extension – what does it mean for companies importing into the EU?

The European Commission has published proposed changes to the Carbon Border Adjustment Mechanism (CBAM) , significantly expanding its scope and strengthening obligations for importers from 2028. This is another step towards fully integrating CO₂ emissions into international trade.

The planned changes have a direct impact on companies importing goods into the European Union and on enterprises operating in global supply chains.

👉 Contact a CBAM Crowe Poland expert.

Changes to Polish legislation

On 18 December, the President of Poland signed an amendment to the Act on the management system for greenhouse gas emissions and other substances, which grants additional powers to tax authorities and environmental protection authorities in relation to CBAM. It can be expected that in 2026, the Polish authority responsible for CBAM (KOBiZE) will begin verification activities regarding CBAM reports submitted for the years 2023–2025. We would like to emphasise that deficiencies in reports or the presentation of unreliable values may lead to the imposition of an administrative penalty of up to €50 for each unreported tonne of CO2 emissions (e.g. for aluminium, approximately €600 for each tonne of imported aluminium).

What is CBAM and what is changing?

CBAM is the EU's border surcharge mechanism for CO₂ emissions, which from 2026 will involve real financial costs for importers of goods with a high carbon footprint.

According to the latest proposal from the European Commission:

the scope of CBAM is to be extended to "downstream" products, i.e. products containing, among others, steel and aluminium, and not only basic raw materials,
mechanisms will be introduced to prevent circumvention of CBAM regulations,
Reporting obligations and technical rules for accounting for emissions will be clarified.

This means that CBAM will cover a much larger share of imports into the EU than before.

Which companies are affected by the changes?

Changes to CBAM will be particularly important for companies that:

import goods into the European Union from outside the EU,
use components or semi-finished products with high emissions (e.g. steel, aluminium, fertilizers, chemical products),
operate in the manufacturing, construction, industrial or commercial sectors,
are part of international capital groups and global supply chains.

In practice, CBAM is no longer a niche regulation – it is becoming an element that can influence the costs, margins and competitiveness of companies.

See the full list of goods and greenhouse gases covered by the CBAM reporting obligation.

What should companies do now?

To prepare for the CBAM expansion, companies should:

analyse the portfolio of imported goods and check whether they can be covered by the new CBAM scope,
identify sources of CO₂ emissions data in the supply chain and verify their availability,
prepare emission reporting processes , also in cooperation with non-EU suppliers,
estimate the potential impact of CBAM on operating costs and product prices,
incorporate CBAM into your ESG strategy and regulatory risk management.

Early preparation helps reduce financial and organizational risks when the regulations fully enter into force.

CBAM - how can we help?

Crowe Poland offers comprehensive CBAM support, including:

analysis of the impact of CBAM on the company's operations and identification of regulated products,
audit of the organization's readiness to report CBAM,
support in collecting and verifying data on CO₂ emissions,
CBAM cost simulations and profitability impact assessment,
ongoing tax, regulatory and ESG advice.