CBAM 2026: How will the EU carbon border affect energy prices in Poland and Europe?
The EU Carbon Border Adjustment Mechanism (CBAM) is not just another EU acronym but a real cost that will appear in company budgets starting in 2026. If you manage energy, gas, or imports in the industrial sector, CBAM may directly impact your costs and energy prices in Poland and across Europe. Learn what the CBAM mechanism is and explore actions that will help prepare your company for 2026. We present practical guidelines that will facilitate budget discussions and further strategic decisions.
CBAM 2026 - what is the EU Carbon Border Adjustment Mechanism?
CBAM (Carbon Border Adjustment Mechanism) is a price adjustment mechanism at the border that accounts for carbon dioxide (CO₂) emissions.
In practice, it is a fee imposed on goods imported from outside the European Union, so that their carbon footprint is accounted for similarly to production within the EU subject to the EU ETS.
In practice, it is a fee imposed on goods imported from outside the European Union, so that their carbon footprint is accounted for similarly to production within the EU subject to the EU ETS.
Key facts about CBAM
- Legal basis: Regulation (EU) 2023/956.
- Purpose: to equalize emission costs between EU producers and exporters from third countries and to limit so-called carbon leakage.
- Scope of products: initially includes steel, aluminum, cement, fertilizers, electricity, and hydrogen - the list may be expanded.
Why is CBAM important for energy and industrial companies?
Even if your company does not directly import steel or electricity from outside the EU, CBAM will affect the costs of many raw materials and energy-intensive products. As a result, it may influence energy prices, construction materials, and even components used in daily production.
CBAM Timeline
Graphic: CBAM introduction schedule
CBAM Implementation overview
- From October 1, 2023 to December 31, 2025 - Transitional period: quarterly reporting of emissions related to the import of CBAM-covered goods. No obligation to pay for certificates. Possible extension of the product list and changes in metrics.
- From January 1, 2026 - Definitive phase begins: obligation to purchase and surrender CBAM certificates corresponding to emissions embedded in imports.
- From 2026 to 2034 - Gradual phase-out of free ETS allowances in CBAM-covered sectors. By 2034, free ETS allocations will end.
CBAM and company budgets - how to calculate certificate costs?
CBAM is a fee system for emissions embedded in imports. An importer bringing CBAM-covered goods into the Union must report how much CO₂ was generated during their production. For every ton of CO₂ emitted, the importer must buy the corresponding number of CBAM certificates. The price of these certificates fluctuates with the EU ETS allowance market, so how this “carbon tariff” works depends on the current emission price.
How do we calculate it in practice?
Below is the calculation method for CBAM certificate costs.
Definition of embedded emissions - The total amount of greenhouse gases (tCO₂e) generated during the production of the imported good (direct emissions + indirect emissions from electricity).
KOBiZE guidance emphasizes that emissions can be demonstrated in two ways: actual data from the producer’s installation or default values published by the European Commission.
The deduction allows for reducing the number of certificates to be surrendered if a mandatory CO₂ fee has already been paid in the country of production.
KOBiZE guidance emphasizes that emissions can be demonstrated in two ways: actual data from the producer’s installation or default values published by the European Commission.
- CBAM benchmark emissions - The standard emission level assigned to a given product, still covered by free allocation in EU ETS in a given year.
- CBAM factor - The percentage of the certificate purchase obligation, increasing each year (e.g., approx. 97.5% in 2026, up to 100%).
- EU-recognized origin carbon price - The carbon fee actually paid in the country of production – it can be deducted if documented and accepted by the EU.
- Embedded emissions - The amount of CO₂ in the product subject to this deduction.
- CBAM certificate price - The current average EUA price – multiplying by this price converts the “deduction” into a real financial value. = 1 tCO₂.
The deduction allows for reducing the number of certificates to be surrendered if a mandatory CO₂ fee has already been paid in the country of production.
Case study: CBAM - steel sector cost calculation example
Theory is one thing, but numbers speak louder. Below we present how the same import volume can generate very different costs depending on the emission data provided by the importer in the CBAM report.
We consider 100 tons of steel imported from outside the EU - our sample product subject to reporting obligations.
We compare two scenarios:
We consider 100 tons of steel imported from outside the EU - our sample product subject to reporting obligations.
We compare two scenarios:
Scenario A: Default values – quick calculation without producer data (higher cost).
The importer did not obtain actual emission data from the producer and therefore uses average emission factors published by the European Commission. This is the fastest, but most expensive, method.
Parameter
Value
Amount of imported steel
100 t
Default emission value
2.60 tCO₂ / t of steel
Total embedded emissions
2.60 × 100 = 260 tCO₂
CBAM factor (2026)
97.50%
Emissions subject to CBAM
260 × 0.975 = 253.5 tCO₂
Cost at EUA price 70 €/t
€17,745
Cost at EUA price 100 €/t
€25,350
Scenario B: Actual data – precise values from the SEE sheet, potentially lower cost.
The producer completed the CBAM Standard Electronic Exchange (SEE) sheet with emission and energy consumption measurements. Thanks to this, the importer can report lower, actual emissions.
Parameter
Value
Amount of imported steel
100 t
Direct emissions
1.20 tCO₂ / t of steel
Electricity consumption
2.08 MWh / t
Electricity emission factor
0.45 tCO₂ / MWh
Indirect emissions
2,08 × 0,45 = 0,94 tCO₂ / t
Total embedded emissions
(1,20 + 0,94) × 100 = 213,6 tCO₂
CBAM factor (2026)
97,50%
Emissions subject to CBAM
213.6 × 0.975 = 208.3 tCO₂
Cost at EUA price 70 €/t
€14,578
Cost at EUA price 100 €/t
€20,826
Comparison of Scenario A and B
Scenario A
Scenario B
Emissions to be settled
253.5 tCO₂
208.3 tCO₂
Cost at 70 €/t
€17,745
€14,578
Cost at 100 €/t
€25,350
€20,826
The same import of 100 tons of steel can cost the importer up to €4,500 more if no reliable emission data is obtained from the producer.
What can you do today?
We understand that the flood of information may be overwhelming. Therefore, we suggest starting with the following steps. These actions will help you navigate the process more effectively.
- Map your CBAM goods suppliers + CN codes and volumes.
- Determine who will provide the SEE (data exchange sheet) and when.
- Secure the electricity emission method (option D.4) and supporting evidence.
- Build two EUA price scenarios (e.g., 70 €/t and 100 €/t) into the 2026+ budget.
- Prepare a quarterly reporting workflow (roles, deadlines, validation).
- Verify whether you fall under the de minimis threshold of 50 t/year.
What to watch out for?
Even the best-prepared company can stumble on details. That’s why we suggest paying attention to the following issues:
- Mismatched CN code vs. customs declaration.
- Confusing country of dispatch with country of production.
- Missing installation/operator data (SEE).
- Use of default values after the permitted period or without specifying the method.
- Undocumented “origin carbon price” (no proof → no deduction).
These mistakes appear most often during the first attempts at preparing CBAM reports and can result in delays or additional costs.
Summary - CBAM
CBAM is a real cost worth managing consciously. Our comparison shows that the difference between “default values” and actual producer data can reach €4–5k per 100-ton steel batch.
The key factor remains the price of EUA allowances, which changes daily and directly affects the total CBAM certificate cost.
Although importers bringing up to 50 tons per year are exempt (de minimis), the mechanism will still cover about 99% of emissions in key sectors.
There may also be an indirect impact of CBAM on electricity prices in countries importing electricity from outside the EU - costs may be passed on to the wholesale market by electricity importers.
The mechanism is still evolving: the European Commission announces further reviews, deregulations, and possible extensions of the product list. It is worth analyzing CBAM’s potential impact on your business and preparing an action plan.
The key factor remains the price of EUA allowances, which changes daily and directly affects the total CBAM certificate cost.
Although importers bringing up to 50 tons per year are exempt (de minimis), the mechanism will still cover about 99% of emissions in key sectors.
There may also be an indirect impact of CBAM on electricity prices in countries importing electricity from outside the EU - costs may be passed on to the wholesale market by electricity importers.
The mechanism is still evolving: the European Commission announces further reviews, deregulations, and possible extensions of the product list. It is worth analyzing CBAM’s potential impact on your business and preparing an action plan.
CBAM - Glossary of terms
- EUA (EU Allowance) - an allowance for emitting 1 ton of CO₂ under the EU ETS, its price determines the CBAM certificate cost.
- Default value - an emission factor published by the European Commission, used when no actual producer data is available.
- SEE (Standard Electronic Exchange) - an electronic data exchange sheet in which a non-EU producer provides actual emissions and energy consumption data needed for CBAM reporting.
- CBAM De minimis - exemption from CBAM obligations for importers who bring in a maximum of 50 tons of covered goods annually.
- CBAM benchmark - reference emission level assigned to a product, used for calculations during the transitional period.
- CBAM factor - the percentage of required certificate purchases, increasing over time (97.5% in 2026, 100% in 2034).
- Embedded emissions - the total carbon footprint of a product (direct and indirect emissions from electricity).
- Origin carbon price - a CO₂ fee paid in the country of production, recognized by the EU and deductible from CBAM costs.
FAQ - CBAM Carbon Border Adjustment Mechanism
What is the CBAM Carbon Border Adjustment Mechanism?
CBAM (Carbon Border Adjustment Mechanism) is the EU’s carbon border mechanism that equalizes CO₂ emission costs between goods produced in the EU and those imported from outside. Importers of CBAM-covered goods must report embedded emissions and buy certificates linked to the EU ETS allowance price.
When does CBAM 2026 take effect in the European Union?
The transitional period lasts from October 1, 2023 to December 31, 2025.
From January 1, 2026, importers will be obliged to purchase and surrender CBAM certificates for emissions embedded in imported goods.
From January 1, 2026, importers will be obliged to purchase and surrender CBAM certificates for emissions embedded in imported goods.
How to calculate CBAM certificate costs?
Cost = (embedded emissions – benchmark emissions) × CBAM factor – (origin carbon price × embedded emissions) × CBAM certificate price.
The certificate price corresponds to the average EUA allowance price on the EU ETS market from the previous week.
The certificate price corresponds to the average EUA allowance price on the EU ETS market from the previous week.
Which goods are covered by CBAM?
Currently, CBAM covers: steel and iron, aluminum, cement, fertilizers, hydrogen, and electricity. In the future, the list may expand to other ETS sectors.
What is the de minimis exemption?
Importers bringing up to 50 tons of CBAM-covered goods annually are exempt from reporting and certificate purchases, as long as their total import volume does not exceed this threshold.
What are “embedded emissions”?
The total amount of greenhouse gases (CO₂e) generated during the production of the imported good – including direct emissions from production and indirect emissions from electricity.
What data must be collected for the CBAM report?
The importer needs an SEE (Standard Electronic Exchange) sheet from the producer with: energy use, direct and indirect emissions, and the country and location of the production facility.
How will CBAM affect energy prices in Poland and Europe?
Directly, CBAM applies to importers of electricity from outside the EU.
However, in countries importing electricity from third countries, there may be an indirect increase in energy prices if importers pass certificate costs onto the market.
However, in countries importing electricity from third countries, there may be an indirect increase in energy prices if importers pass certificate costs onto the market.
What does a deduction in CBAM mean?
If a local carbon fee recognized by the EU was paid in the country of production, the importer can reduce the number of required certificates by the equivalent of the fee already paid.
What are the penalties for non-compliance with CBAM?
Failure to report or purchase certificates results in a financial penalty imposed by national authorities, calculated on the missing number of certificates and linked to the EUA price.
Author: Jakub Bartnicki
