Policy Briefing — October 31, 2025

Executive briefing: The transitional phase of Regulation (EU) 2023/956 on the Carbon Border Adjustment Mechanism (CBAM) obliges importers of iron and steel, aluminium, cement, fertilisers, hydrogen, and electricity to file quarterly emissions reports. The report covering imports from July through September 2025 is due by October 31, 2025. Firms must reconcile embedded emissions, carbon prices paid abroad, and product classifications before the definitive CBAM regime—with certificate purchases—begins on January 1, 2026.

Key policy checkpoints

Data completeness. Verify supplier declarations capture direct and indirect emissions in accordance with the Commission’s implementing regulation (EU) 2023/1773.
Verification evidence. Maintain documentation showing how emissions data were calculated or estimated, including fallback methodologies approved for the transitional period.
Price adjustments. Track any carbon taxes or ETS allowances already paid in the country of origin to deduct them from future CBAM certificates.

Operational priorities

CBAM registry readiness. Ensure authorised declarants have access to the EU CBAM Transitional Registry and that data pipelines feed accurate customs and emissions records.
Supplier engagement. Run outreach programmes with non-EU mills and smelters to standardise emission factor submissions ahead of the 2026 monetary phase.
Scenario planning. Model 2026 compliance costs under different EU Allowance price assumptions and contract clauses for cost pass-through.

Enablement moves

Align CBAM reporting with CSRD and EU Taxonomy disclosures to present a unified climate transition narrative to investors.
Coordinate with customs brokers to validate CN codes and ensure dual-filing accuracy between CBAM submissions and customs declarations.

Sources

Zeph Tech integrates emissions accounting, customs data, and scenario modelling so trade and sustainability leaders can meet CBAM deadlines without disrupting supply chains.