CBAM Assessment Missed Deadline by 153 Days
The Commission failed to release full datasets, leaving importers guessing on upcoming compliance costs.
Updated on Oct. 5, 2026 in International Trade

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DG TAXUD reported that a 50-tonne exemption threshold covered only 0.87 percent of embedded emissions between April 2025 and March 2026. This assessment arrived 153 days after the original statutory deadline, and the Commission provided no methodology or supporting dataset.
Why it matters
The delay and lack of transparency regarding calculation methods create uncertainty for businesses needing to forecast carbon compliance costs. As the mechanism for crediting foreign carbon payments remains stalled, operators face growing friction in their supply chain planning.
The 50-tonne threshold exempted 0.87 percent of emissions against a 1 percent statutory ceiling. Meanwhile, the regulation for crediting foreign carbon costs remains pending, with certificate sales currently scheduled to begin on February 1, 2027.
The players
DG TAXUD
The European Commission's Directorate-General for Taxation and Customs Union responsible for implementing trade-related tax policies.
European Commission
The executive branch of the European Union responsible for proposing legislation and managing the bloc's administrative affairs.
The details
The Commission's notice and factsheet provide only the top-line percentage result rather than the granular data necessary for business compliance and verification. Because the legal act for certificate sales and the rules for crediting foreign carbon payments have not been adopted, importers are left without clear guidance on how to manage their tax liabilities. The delay effectively leaves businesses in the dark regarding how to account for carbon costs paid in their countries of origin.
Timeline
April 2025 - March 2026: Period covered by the CBAM threshold assessment.
April 30, 2026: Original deadline for the Commission assessment.
May 13, 2026: Date the carbon credit regulation draft became available.
September 30, 2026: Date DG TAXUD released the threshold notice.
February 1, 2027: Scheduled start of CBAM certificate sales.
Market Landscape
This lack of transparency marks a departure from the predictable regulatory rollout expected for the Carbon Border Adjustment Mechanism. It highlights an emerging administrative gap that complicates long-term cost forecasting for international trade participants.
Operators should prepare for ongoing uncertainty regarding carbon credit deductions and certificate costs as the legal framework remains incomplete. Finance teams should monitor the fourth-quarter 2026 release of the delegated act to adjust cost projections before February 2027.
The takeaway
The Commission's failure to provide a methodology note for its assessment signal significant risks for supply chain cost modeling. Importers should track the pending status of the carbon credit regulation and prepare for possible cost volatility when certificate sales commence in early 2027.
What happens next
The delegated act regarding CBAM certificate sales is expected in the fourth quarter of 2026, ahead of the February 1, 2027, launch.
Further reading
For broader trends in global compliance, see the latest updates in International Trade.
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