The key point for 2026 is this: CBAM moves from “reporting only” to a definitive regime where, broadly speaking, importing CBAM goods requires being authorised and managing compliance in the CBAM Registry. This CBAM Carbon Border Adjustment Mechanism practical guide for Italian companies helps you understand whether you are in scope, which data you need to collect from non‑EU suppliers, how to set up the workflow, and how to estimate the cost.
Who must apply CBAM in Italy and which goods/imports are currently in scope (sectors, customs codes, exclusions)
What matters is who imports into the EU, not who “buys” commercially. The CBAM declarant is, in practice, the importer established in the EU or an indirect customs representative who lodges the customs declaration in their own name on your behalf. From 1 January 2026, importing CBAM goods generally requires Authorised CBAM Declarant status, to be requested and managed via the CBAM Registry/AMM (authorisations management module). For Italy-based operators, this applies to imports cleared through Italian customs as part of the EU customs territory. Source: Commission Implementing Regulation on conditions and procedures for authorised declarant status (28/03/2025)
CBAM scope today is defined by customs codes, not by product descriptions. The covered sectors are 6: cement, iron and steel, aluminium, fertilisers, hydrogen, electricity. You check scope using 8‑digit CN codes (Combined Nomenclature), line by line, as set out in the regulatory annexes. Source: European Commission list of CBAM sectors
A practical example helps avoid typical purchasing-office mistakes. If you import steel screws/fasteners, they may be in scope if the code is CN 7318…: it’s not enough to say “it’s fasteners”—you must verify whether that specific CN code is listed in Annex I (and under what conditions). Source: sectors and CN-based logic; check Annex I of the CBAM Regulation
The practical rule for buyers and customs teams is: map first, confirm second. Start from the typical HS/CN families (useful examples: 72/73 for iron and steel, 76 for aluminium, 2716 for electricity), then confirm line by line against Annex I and your broker’s working list. CN checking tools can help as a first filter, but they do not replace Annex I. Source: CN check tool (operational support)
Exclusions and special cases matter more than they seem. If you import under outward processing (EU goods processed outside the EU and re‑imported), the declaration reports only the emissions from the non‑EU processing, not the “historic” emissions of the original EU good. And watch out for “reclassification”: minor product changes aimed at moving out of in-scope CN codes are a compliance risk, because CBAM relies on customs classification and controls. Source: Regulation (EU) 2023/956 (CBAM)
Decision checklist (use for every SKU/import flow):
- Non‑EU (extra‑EU) import?
- Goods with an 8‑digit CN code listed in Annex I?
- Incoterms and contracts: who is the importer of record at customs?
- Customs representation: direct or indirect? (this changes who becomes the declarant)
- Volumes and frequency: how many shipments, how many customs lines, how many plant variants?
Recommended output: an SKU/CN table with a “CBAM yes/no” column + rationale (Annex I line, notes on outward processing, exceptions).
What data is needed for the CBAM declaration: embedded emissions, calculation methodologies, and documents to request from non‑EU suppliers
Embedded emissions are the core data point. For CBAM, embedded emissions are the emissions associated with producing the imported goods within the CBAM boundary, and they are split into:
- Direct: emissions from the production process (combustion, chemical reactions, etc.).
- Indirect: emissions linked to electricity consumed in production, where applicable under CBAM rules and implementing acts. Source (CBAM training material on scope and definitions):
Data quality changes the economic risk. The practical hierarchy is: producer’s actual data (preferred) vs default values published by the Commission (usable in the transitional phase with flexibility). From a cost perspective, actual data reduces the risk of overestimation versus standard values. Source: Commission publication of default values (transitional period)
The “data pack” to request from the non‑EU supplier should be built into the contract. In procurement, a single template works well, requesting at least:
- Production installation (site) and unique identification
- Data reference period
- Product output (t) and quantities supplied (t) for the period
- Emission factors and/or calculations leading to tCO₂/t
- Energy consumption and electricity share (if applicable)
- Methodology applied and assumptions
- Available evidence (audit/assurance if any)
- Carbon price paid in the country of origin, with documentary proof Source (overview of reporting requirements and carbon price evidence):
Concrete example (Italian processor). If you import steel coil, you need: (i) tonnes imported by CN code, (ii) tCO₂/t for the production site, (iii) indirect electricity share where applicable, (iv) any local carbon price paid and documented. Output: embedded tCO₂ per shipment and totals for the period (quarter/year, depending on the obligation).
Data governance: if you don’t set it up, you end up chasing it. Create a CBAM master dataset with CN, supplier, site, emission factor, documents and versioning. Then link it to ERP/PLM and customs flows (SAD, invoices, packing lists), so you avoid rebuilding everything manually at every deadline.
How to compile and submit the CBAM report in the Registry: deadlines, internal workflow, and checks to avoid errors and penalties
The timeline changes the type of work. The 2023–2025 transitional phase is reporting without payment, while the definitive regime starts on 1 January 2026: authorisation, annual declaration and management of CBAM certificates come into play under the applicable rules. Source: Commission CBAM page and timeline
A typical workflow works if it is repeatable and traceable:
- Extract imports by 8‑digit CN from broker/customs (for the period)
- Enrich with emissions data from the supplier (site, factors, evidence)
- Consistency checks (units, net mass, conversions, duplicates)
- Upload to the CBAM Registry
- Retain evidence and audit trail (who validated what, when, with which documents)
The most useful anti-error checks are the “basic” ones that still cause submissions to fail:
- 8‑digit CN in the declaration not consistent with the actual material (classification error)
- Quantities: kg vs t, net vs gross mass, conversions
- Multiple sites for the same supplier (different emission factor)
- “Split” shipments and duplicate customs lines
- Outward processing handling (only emissions from non‑EU processing)
- Duplications between subsidiaries or between importer and indirect representative
- Credit notes and customs adjustments that change quantities and values
Responsibilities and delegation: outsourcing does not mean offloading the risk. Even if a customs representative operates, compliance responsibility remains with the importer: you need formal mandates, a clear RACI, and second-level checks on high-impact samples.
Internal “project” deadlines: close data by T+10 after period end, reconcile with supplier accounting, and plan a pre-submission review (sampling high-impact shipments, checks on CN and site).
How to estimate the CBAM cost: EU ETS price, CBAM certificates, and how to account for any carbon price paid in the country of origin
CBAM cost follows the EU ETS price. CBAM certificates are expressed in €/tCO₂ and their price is linked to the EU ETS auction price. Operational note. Source: Commission on first certificate price publication and averaging rules for 2026/2027
CFO-style formula for a first estimate: Estimated CBAM cost = embedded tCO₂ (direct + applicable indirect) × CBAM price – credit for foreign carbon price (if recognisable and documented)
In the transitional period, foreign carbon price was mainly collected as information; in the definitive regime it may affect what is due, subject to recognition and evidence rules. Source: reporting requirements and carbon price evidence (transitional)
B2B numerical example (only to understand the order of magnitude, not a forecast):
- 1,000 t imported
- 2.0 tCO₂/t embedded
- Total: 2,000 tCO₂
- Hypothetical ETS price: 70 €/tCO₂
- “Gross” cost: 2,000 × 70 = €140,000 Then apply any deduction for foreign carbon price, if you have documents such as invoices, proof of payment, applicable rates, and a clear link to the product/site.
Estimation risks to factor in:
- Use of default values (possible overestimation versus actual site data)
- Site electricity mix and process variations
- Errors mapping CN to the correct category
- EU ETS volatility: run scenario analysis (-20% / base / +20%) on the price
Link the estimate to contracts, not just reporting. The “CBAM landed cost” by supplier and site is needed to renegotiate, change sourcing, or add clauses on emissions data and carbon price (data delivery obligation, auditability, pass-through cost management).
90-day operational plan to get compliant: roles (procurement, customs, ESG), IT systems, and a ready-to-use checklist
In 90 days you need a process that runs, not a perfect file. Structure it into 3 sprints with clear minimum outputs.
Sprint 0–30 days (scoping)
Goal: know what is in scope and who does what.
- Extract last 12 months of non‑EU imports by 8‑digit CN
- Flag “CBAM yes/no” based on Annex I
- Identify importer of record and type of customs representation
- List suppliers and sites (even if incomplete) Output: in-scope CN list, supplier list, draft RACI
Sprint 31–60 days (data & process)
Goal: get data from suppliers and make it comparable.
- Send data request pack to non‑EU suppliers (template + evidence)
- Create document repository and naming/versioning rules
- Define data quality checks (units, site, period, consistency) Output: approved template, repository, first supplier responses, written process
Sprint 61–90 days (run & audit)
Goal: dry run and audit trail.
- Simulate a full cycle for one period (or a high-impact sample)
- Upload to the CBAM Registry (or prepare an upload-ready dataset)
- Run internal review and remediation on exceptions Output: evidence, gap list, plan for non-cooperative suppliers
Recommended RACI:
- Procurement: contracts, data clauses, supplier collection
- Customs/Trade compliance: CN, import flows, broker, outward processing
- ESG/HSE: emissions methodologies and technical checks
- Finance: cost estimate, scenarios, provisions
- IT/Data: ERP integration, broker files, data model, access and audit trail
Ready checklist (operational):
- Verify 8‑digit CN for each imported SKU
- Define importer of record and direct/indirect representation
- Supplier onboarding with emissions and carbon price template
- Document repository with evidence
- Data quality checks and exception handling
- Deadline calendar and internal closes
- Remediation plan for non-cooperative suppliers (default values, escalation, alternative sourcing)
Realistic IT stack:
- SMEs: extraction from ERP + broker files, data model in BI (e.g., Power BI/Tableau), approval workflow (SharePoint/Jira), evidence retention
- Large importers: EDI integration, supplier MDM, automated checks on CN and site
KPIs that truly help:
- % of CBAM imports with actual data vs default
- Supplier response lead time
- Number of exceptions per period (CN/site/unit)
- CBAM cost delta per tonne and per supplier
Strategies to reduce CBAM impact: supplier selection, supply-chain decarbonisation, and integration with CSRD/Scope 3 reporting
The main lever is selecting sites with lower tCO₂/t. In procurement, reward plants with lower-emission processes and energy (for example, for steel, sites using EAF with good access to low-emission electricity; for aluminium, smelters with low-emission power sourcing, where verifiable). Add a “CBAM clause” to contracts: data obligation, auditability, penalties, carbon cost pass-through, and a supplier scorecard based on tCO₂/t.
Technical levers also reduce complexity. Reducing mass and scrap, increasing recycled content where applicable, changing semi-finished inputs or specifications can lower embedded intensity or imported volume. Optimising logistics and consolidating shipments does not reduce CBAM directly, but it reduces total costs and operational risk (fewer customs lines, fewer exceptions).
Supplier enablement: if suppliers don’t know how to measure, you pay for uncertainty. Provide training on methodologies, energy/process data collection, and an improvement roadmap. The practical goal is to reduce reliance on default values and improve MRV quality.
Align CBAM with CSRD and Scope 3 to avoid doing the work twice. Use the same dataset for emission factors, sites, evidence and document traceability. Define an internal “single source of truth”, with clear ownership across ESG, customs and finance.
Strategic governance: plan ETS/CBAM scenarios and multi-year budgeting. Assess nearshoring/reshoring vs non‑EU sourcing with a full view: CBAM cost, customs risks, lead time, contractual stability and data quality.
