Executive summary

On 28 August 2025, the European Commission opened three Calls for Evidence under the Carbon Border Adjustment Mechanism (CBAM). Each initiative addresses a separate regulatory aspect of CBAM and invites stakeholder feedback until 25 September 2025. These consultations are part of the transition toward the definitive CBAM regime from 1 January 2026. Businesses affected by CBAM are encouraged to engage with the consultation process to ensure that practical realities are reflected in the final regulations.

Background

The CBAM is a central pillar of the European Union's (EU's) climate strategy, designed to prevent carbon leakage and ensure that imported goods are subject to the same carbon costs as those produced within the EU. As the transitional phase of CBAM continues, the European Commission is preparing for the definitive regime that will begin on 1 January 2026. In support of this transition, three separate Calls for Evidence have been launched, each targeting a specific regulatory challenge aiming to refine the CBAM framework, reduce administrative burdens and ensure fair treatment of importers.

Call to action

The European Commission is inviting CBAM affected businesses, in both EU and non-EU countries, to provide input into the shaping of key implementing regulations for the definitive period starting on 1 January 2026. The Call for Evidence gives affected parties the opportunity to provide input on CBAM developments that will have future data, process, compliance and financial implications.

1. CBAM emissions calculation methodology for the definitive period

The method of calculating direct embedded emissions, indirect embedded emissions, and the use of default values, will change when the Definitive Period starts on 1 January 2026. Taken this development, this Call for Evidence invites stakeholders to provide input regarding:

• Calculation of direct embedded emissions
• Determination of embedded emissions for electricity
• Determination of embedded indirect emissions
• Setting and using default values

The calculation methodology is key for EU importers to quantify their CBAM certificate (and cost) obligations.

2. Adjustment of CBAM certificates to reflect free EU ETS allowance

In the Definitive period, a calculation methodology for the CBAM certificate obligation based on EU Emissions Trading System (EU ETS) free allowances will be established to align CBAM certificate obligations with the EU ETS. The regulation will define the methodology for calculating embedded free allocation and will determine the CBAM benchmarks in alignment with the EU ETS benchmarks.

3. Recognition of carbon price paid in third countries

In the definitive period, EU importers will be able to convert the carbon price paid in non-EU countries into a corresponding number of CBAM certificates, thereby reducing their certificate purchasing obligations. The European Commission is also considering compensation mechanisms in countries that reduce the effective carbon price, aiming to ensure fairness and avoid double carbon pricing for goods imported into the EU.

The regulation will define the methodology for recognition and conversion, including documentation and verification requirements.

Implications

These three initiatives will shape the future of CBAM data and process obligations, compliance and ultimately costs. Businesses importing CBAM-covered goods should carefully review each proposal and consider submitting feedback. The outcomes will influence how emissions are calculated, how costs are allocated and how international carbon pricing is recognized. Engaging in the consultation process offers a valuable opportunity to help shape practical, effective rules that reflect operational realities and support strategic planning.