CBAM and EUDR: what changes for exporters and importers in 2027

In 2027, the CBAM becomes an actual expense: from 1 February 2027, European importers of steel, aluminium, cement, fertilisers, hydrogen and electricity buy the certificates covering their 2026 imports, then declare and surrender them by 30 September 2027. The EUDR applies from 30 December 2026 to medium-sized and large companies that place on the market or export cocoa, coffee, wood, rubber, soya, palm oil or cattle. In both cases, compliance depends on data that only the supplier can produce.

Two definitions. The CBAM (Carbon Border Adjustment Mechanism) makes imports pay for the carbon emitted during their manufacture, at the price of the European carbon market. The EUDR (EU Deforestation Regulation) requires proof that certain commodities do not come from land deforested after 31 December 2020 and were produced legally (Regulation 2023/1115).

Which products does the CBAM cover, and who has to pay?

The CBAM has been in its definitive phase since 1 January 2026. It covers imports from six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen (European Commission).

The liable party is the importer established in the EU, not the foreign supplier. Since Regulation 2025/2083 of 8 October 2025, an importer whose purchases of these goods, excluding electricity and hydrogen, do not exceed 50 tonnes a year is exempt; above that, it must be an authorised CBAM declarant (EUR-Lex). If the threshold is crossed during the year, all of that year's imports become subject to the obligations (PwC).

What does 2027 change for importers?

The timetable for the first full year is now set:

• 1 February 2027: certificates go on sale on a common central platform (ICAP, 19 January 2026).
• Price: quarterly average of European carbon market auctions in 2026, weekly average from 2027 (EPA Ireland). The price for the first quarter of 2026 was set at €75.36 per tonne of CO2 (S&P Global, 7 April 2026).
• 30 September 2027: declaration of the emissions embedded in 2026 imports and surrender of the corresponding certificates (EPA Ireland).
• End of each quarter, from 2027: hold certificates covering at least 50% of the emissions imported since the start of the year (EPA Ireland).

The bill remains moderate at first, because it tracks the gradual phase-out of free allowances for European producers: the reduction is 2.5% a year in 2026 and 2027 (ICAP), until free allowances disappear completely in 2034 (Reed Smith).

Supplier data has a direct impact on cost. Without verified actual data, the importer applies default values marked up by 10% for 2026, 20% for 2027 and 30% from 2028, with fertilisers following a separate regime (ICAP).

Will the extension to downstream products affect SMEs?

Probably, but its scope has not been settled. On 17 December 2025, the Commission proposed extending the CBAM to around 180 downstream steel and aluminium products from 1 January 2028 (ICAP). The Council adopted its position on 12 June 2026 covering around 200 products, and Parliament its own on 15 September 2026 covering around 457, including screws, bolts, wire, tubes and metal furniture; the first trilogue is scheduled for 20 October 2026 (Mayer Brown, 7 October 2026).

An SME importing metal components could therefore become a declarant in 2028. It is advisable to identify the potentially affected flows now, then adjust the list once the text is adopted.

What does the EUDR require, and from when?

The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soya, wood and certain derived products. It requires geolocation of the plots of land where they were produced, also applies to products exported from the EU and provides for fines with a maximum amount of at least 4% of annual turnover generated in the Union (Regulation 2023/1115).

Amending Regulation 2025/2650 postponed and simplified its application (European Commission, 28 January 2026):

• 30 December 2026 for large and medium-sized companies, and for micro and small enterprises in respect of products already covered by the former Timber Regulation;
• 30 June 2027 for other micro and small enterprises;
• the due diligence statement is the sole responsibility of the operator that first places the product on the market; downstream operators and traders keep the reference number of that statement, and those that are not SMEs register in the information system;
• micro and small primary operators established in a low-risk country submit a simplified declaration.

The country classification dates from 22 May 2025: Belarus, North Korea, Myanmar and Russia are high risk, EU Member States among others are low risk, and all other countries standard risk (Implementing Regulation 2025/1093). Each year, the authorities check at least 1%, 3% or 9% of operators depending on that risk level (Regulation 2023/1115).

On 13 July 2026, the Commission removed six product families from the scope, including bovine hides and skins, retreaded tyres and aircraft and vehicle seats, and added three, including soluble coffee; the new products come into scope on 30 December 2027 (European Commission).

Is the United Kingdom creating a second CBAM?

Yes. The UK CBAM starts on 1 January 2027 for aluminium, cement, fertilisers, hydrogen, iron and steel. The liable party is the importer in whose name the customs declaration is made, from £50,000 of relevant imports; it may use the producer's verified actual data or published default values. The first return and the first payment are due on 31 May 2028 (GOV.UK, 9 September 2026). A French exporter of steel or aluminium will therefore receive data requests from its UK customers.

Who needs to prepare what, on the exporter side and the buyer side?

The EU CBAM covers only imports into the EU: it creates no obligation for a sale outside the Union, apart from the destination country's own rules, as in the United Kingdom.

Where to start before the end of 2027?

1. Map the flows: customs codes imported and exported, 2026 volumes per supplier, comparison with the 50-tonne threshold.
2. Obtain supplier data: verified emissions per installation for the CBAM, geolocation and legality for the EUDR. Write these into purchase contracts.
3. Budget for certificates on the basis of 2026 volumes and published prices, factoring in the 50% quarterly holding requirement from 2027.
4. Respond to buyers: an exporter able to provide this data to its customers, European or British, removes an obstacle to the order.
5. Follow the trilogue on the downstream extension and the updates to the EUDR scope, which will change the list of products concerned in 2027 and 2028.