CBAM, good intentions aren’t enough: the supply chain’s missing piece

The intentions were good: with the CBAM (Carbon Border Adjustment Mechanism), the EU set out to align the cost of CO₂ emissions on products imported from non-EU countries with that of goods manufactured within the Union.

A mechanism designed to prevent carbon leakage — that is, to stop companies from relocating production to countries with less stringent environmental regulations — to ensure fair competitive conditions between European and non-EU producers, and to encourage trading partners to reduce their own greenhouse gas emissions.

So far, no argument there. But while it’s true that everyone must play their part, it’s equally true that in practice it’s mainly the upstream players in the supply chain who are called to account: producers of carbon-intensive raw materials, such as steel, aluminium and cement. The risk is an imbalance between those who are protected — European producers — and those who remain more exposed — the downstream manufacturing sector, which imports components and semi-finished goods with embedded carbon without benefiting from the same protections.

On top of this comes a methodological issue: as of 1 January 2026, importing raw materials from non-EU countries requires “authorised declarant” status. Companies must report the emissions embedded in imported goods and purchase dedicated CBAM certificates to offset them. The problem is that the amounts due are not yet fully defined: companies can calculate the cost in two ways — either by tracing the supplier’s actual carbon footprint, still difficult to obtain in non-European markets and pending the European Commission’s publication of the list of accredited verifiers who will need to check and validate data from non-EU producers, or by using default reference values, which result in a higher cost than calculations based on actual data.

“The project itself follows a logic I agree with: the polluter pays, and there’s no doubt about that,” comments Alberto Schiavo, Cardinali Holding Chief Commercial Officer. “The problem is the implementation phase: companies find themselves having to make important operational decisions — how to calculate emissions, which data to use, which suppliers to engage with — without definitive guidance from the authorities. Companies end up having to move ahead of rules that aren’t yet fully defined.”

As CPC Inox, we chose to comply with CBAM obligations already during the transitional period, getting ahead of the requirements before they became mandatory, and we have already obtained authorised declarant status. For our customers, this translates into continuity of supply, a focus on traceability, and partners who are already committed to the process of monitoring and measuring their own emissions.

“Getting ahead of the timeline doesn’t mean we’ve eliminated regulatory uncertainty, which remains,” Schiavo adds, “but it does mean our customers don’t have to deal with it: we’re managing it ourselves, upstream, while the framework is being finalised.”

The topic remains widely debated among supply chain players, also in light of a figure worth remembering: European producers account for around 6% of global CO₂ emissions (source: Eurostat, 2023). This is a factor that should push toward safeguard policies more attentive to protecting the sector that, today, represents the true added value of the European market.