СВAM Reporting Services

CBAM: Key Information

The Carbon Border Adjustment Mechanism (CBAM) is a European Union climate policy instrument designed to combat climate change and prevent "carbon leakage". Carbon leakage occurs when production is transferred from the EU to countries with less ambitious climate policies, or when EU products are replaced by more carbon-intensive imports.

The essence of the mechanism: CBAM sets a price on the Embedded Emissions in certain goods imported into the customs territory of the EU. Importers of these goods will be required to purchase and surrender special CBAM certificates, the price of which will be linked to the average weekly price of allowances within the EU Emissions Trading System (EU ETS). The goal is to equalise the "carbon price" for imported and domestic EU products, incentivising cleaner production worldwide.

From 1 January 2026, the reporting process within CBAM has ceased to be a purely statistical exercise. It is now a legally binding procedure that determines the number of certificates to be purchased and cancelled by the importer in the EU.

 

Legislation and Recommendations on CBAM

 

ECO-STREAM offers comprehensive support based on the requirements of Regulation (EU) 2025/2083 (Omnibus) and the methodology of Regulation (EU) 2025/2547.

 

Why is this important?

CBAM is necessary to:

  1. Avoid additional costs for carbon certificates.
  2. Ensure reporting in accordance with EU rules and maintain access to the European market.
  3. Strengthen your business's position as a reliable, environmentally responsible supplier.
  4. Reach a new level of attracting "green" financing.

Who needs this?

  • Directly: Importers in the EU (or their indirect customs representatives) who import goods covered by the mechanism from countries outside the EU and the European Free Trade Association (EFTA), with the exception of certain territories.
  • Indirectly: Manufacturers (exporters) from third countries whose products are supplied to the EU. They become key providers of data on Embedded Emissions for European importers.

 Sectors covered in the initial phase (from the transition period):

  • Iron and steel (including certain derivative products, e.g., screws, bolts)
  • Cement
  • Fertilisers
  • Aluminium
  • Electricity
  • Hydrogen

The Client's Problem

From 2026, the import of CBAM goods into the EU involves real operational and financial risks. The lack of Authorised CBAM Declarant status or errors in TARIC codes (Y128, Y238, Y137) can lead to delays or blocking of customs clearance, disruption of supplies, and additional costs.

An additional challenge is the complexity of applying CBAM requirements in practice. Due to a lack of accurate data on actual emissions, companies often use Default Values, which automatically increases the need for CBAM certificates and raises costs. Consequently, businesses face three key problems: the risk of import delays, regulatory complexity, and overpayment due to inflated calculated emissions.

We mitigate your risks and transform the complex formulas of Regulation (EU) 2025/2547 into clear business solutions, minimising your costs for carbon certificates by using Actual Data instead of Default Values.

Do not pay more for carbon than necessary. Prepare correctly with the ECO-STREAM team.

How We Solve the Problem

1. Authorisation of the Declarant and Management in the CBAM Registry

  • Preparation and submission of applications for "Authorised CBAM Declarant" status through the customs authorities of EU Member States.
  • Company registration in the Authorisation Management Module (AMM) and the UUM&DS digital signature system.
  • Work with the Operators in Third Countries Installation (O3CI) module for the secure transfer of emissions data from the manufacturer to the importer.

2. Development and Implementation of an Emissions Monitoring System

  • Analysis of production processes in accordance with Regulation (EU) 2025/2547, including identification of the Installation Boundary and emission sources.
  • Calculation of actual Embedded Emissions (Direct Emissions and Indirect Emissions) per unit of product using EU methodology.
  • Accounting for emissions from Precursors and specific industry benchmarks set by the European Commission for the definitive period.

3. Preparation of the Annual CBAM Declaration

  • Formation of the annual report (instead of quarterly), the first submission of which for 2026 must take place by 30 September 2027.
  • Completion of the official CBAM Communication File with details for each CN code and Production Route.
  • Accounting for the "carbon price effectively paid abroad" (Carbon Price Paid) to reduce the number of certificates for cancellation.

4. Financial Consulting and Forecasting

  • Assessment of the financial impact of CBAM on product cost based on weekly EU ETS auction prices.
  • Management of the "50% rule": ensuring the presence of certificates in the Registry account in an amount of at least 50% of the Embedded Emissions from the beginning of the year at the end of each quarter.
  • Consulting on the certificate procurement strategy (sales of which begin on 1 February 2027).

5. Internal Verification and Advisory Support

  • Verification of prepared calculations for compliance with European CBAM requirements.
  • Providing recommendations for further process optimisation to reduce carbon emissions.

CBAM Verification: Confirmation of Data for the European Market

Your passport to barrier-free export from 2026

From 1 January 2026, no CBAM Declaration based on actual data can be submitted without confirmation by an independent accredited verifier. Verification from Eco-Stream is a guarantee that your emissions report will be accepted by any National Competent Authority (NCA) in the EU, and your carbon costs will be optimised.

Why Verification with ECO-STREAM is Your Competitive Advantage

We approach the CBAM verification market as a company systematically integrated into the legal and institutional field of the EU. ECO-STREAM is processing several strategic models to ensure service continuity, legal correctness, and full compliance with Regulations (EU) 2025/2551 and 2025/2546.

Our strategy includes:

  • Access to the European accreditation system and regulatory infrastructure.
  • Possibility of physical presence at production sites in Ukraine.
  • Integration of Ukrainian expertise into the European decision-making system.
  • Flexibility of the operating model considering changes in the regulatory environment.

The Verification Process under the 2026 Standard

  1. Audit of the Monitoring System and Monitoring Plan (MP): Verifying compliance of your internal accounting with Regulation (EU) 2025/2547 and analysis of Inherent and Control risks.
  2. Mandatory Site Visits: Fulfilment of the requirement for mandatory physical presence at the installation in the first year of verification. If a visit is impossible due to hostilities, Remote Assessment procedures using video recording are applied, subject to agreement with the EU accreditation body.
  3. Detailed Data Verification: Analysis of the "chain of evidence" for every figure in the report—from primary documents (invoices, certificates) to aggregated values in the declaration. Verifying the correctness of emission factors and Net Calorific Value (NCV) calculations according to the EU Tiers hierarchy.
  4. Issuance of the Verification Report via the EU Registry: Preparation of the final conclusion using a unified EU electronic template, uploaded directly into the CBAM Registry. Independent review of the report by the Polish office to confirm objectivity.

Strategic Preparation: Gap Analysis (Pre-verification)

We recommend starting with a Gap Analysis (Pre-verification) today. This allows your company to:

  • Assess the maturity of the monitoring system under the new rules of the definitive period.
  • Identify and eliminate systemic calculation errors without the risk of fines.
  • Prepare personnel and documentation for the official audit by European assessors in 2027.

Your Result:

A verified report with Eco-Stream is your entry ticket to global supply chains where carbon footprint transparency is a basic contract condition.

 

 

 

Would you like we to draft a sample project timeline for a Gap Analysis (Pre-verification) to help your technical team prepare for the 2026 deadline?

Contact our experts

Contacts

Kyiv city, Mykoly Vasylenka street, 7А hello@eco-stream.com.ua +380 (50) 680 92 32