CBAM is in force: CO₂ emissions have a price
With the Carbon Border Adjustment Mechanism (CBAM), EU climate policy has entered a new phase as of early 2026. For the affected product groups, greenhouse gas emissions are no longer merely a reporting item, but are now associated with explicit costs per tonne of CO₂ equivalent. The price of CBAM certificates is linked to the EU Emissions Trading System and is set on a quarterly basis. It currently (May 2026) amounts to €75.36 per tonne of CO₂ equivalent.
The European Commission has recently published the relevant reference values on which CBAM certificates are priced. This makes it clear that embedded emissions now have a direct impact on import costs.
ESU-services helps you to identify potential savings under EU’s CBAM by analysing greenhouse gas emissions throughout your supply chain:
Who is affected by CBAM?
CBAM applies to imports into the EU of the following product groups:
- Iron and steel
- Aluminium
- Cement
- Fertilisers
- Electricity
- Hydrogen
CBAM directly affects EU importers, but indirectly also non‑EU manufacturers supplying these products to the EU market. Without robust emissions data from the supply chain, EU‑wide default values are applied — and these are typically significantly higher than realistic, well‑documented production values.
Embedded emissions are no longer estimates
At the core of CBAM are so‑called embedded emissions. These include the greenhouse gas emissions generated during the production of the imported goods.
CBAM clearly distinguishes between two product types:
Simple goods:
Emissions from direct production processes as well as from consumed electricity and heat.
Complex goods:
In addition, the emissions of relevant precursor products used to manufacture the final product.
System boundaries are defined on a product‑specific regulatory basis and do not simply follow a generic cradle‑to‑gate approach. The decisive factor is the regulatory definition, not ISO logic alone.
Why default values can become costly
During the transitional phase, many companies relied on approximations or simplified data. From 2026 onward, this fundamentally changes.
If no product‑specific emissions data can be provided, EU default values must be used. These are deliberately conservative to prevent carbon leakage. In practice, this means:
Missing data do not reduce effort — they increase costs.
A robust life cycle assessment can therefore make a significant difference, not only environmentally but also economically.
The role of life cycle assessment in the CBAM context
Life cycle assessments (LCA) provide the methodological basis for correctly determining CBAM‑relevant emissions. Key aspects include:
- clearly defined system boundaries in line with CBAM requirements,
- consistent data sources across the supply chain,
- transparent assumptions and documentation,
- alignment with regulatory requirements, not only ISO standards.
CBAM therefore illustrates how regulatory requirements and LCA practice are increasingly converging, and why methodological quality is becoming ever more important.
How we support companies with CBAM
In our view, the main challenges lie not only in calculation, but in the interaction between methodology, data availability and regulation.
ESU‑services supports companies in particular with:
- calculating embedded emissions in accordance with CBAM rules,
- methodologically classifying products (simple vs. complex goods),
- collecting and validating data from suppliers,
- critically reviewing existing emissions data and models,
- bridging classical life cycle assessment and regulatory application.
The objective is to prepare emissions data in a way that is methodologically robust, transparent and suitable for regulatory use.
Outlook: CBAM is only the beginning
CBAM does not stand alone. Other EU instruments are advancing in parallel, in which life cycle assessments play a central role: the Digital Product Passport, Ecodesign requirements, the EU Battery Regulation and CSRD.
All these initiatives follow a common trend: environmental impacts must be measurable, transparent and comparable.
CBAM is the first instrument to make this principle immediately enforceable, with direct effects on costs, competitiveness and market access.
ESU‑services has been supporting companies for many years in the preparation, assessment and interpretation of life cycle assessments, including in the context of new regulatory requirements. CBAM clearly shows that methodology is not a minor detail , it is decisive.
