The Carbon Border Adjustment Mechanism is the EU’s landmark policy to prevent carbon leakage by placing a carbon price on imports of carbon-intensive goods. Importers must report and eventually purchase CBAM certificates corresponding to the embedded emissions of their products. Compliance requires verified emissions data, which means accredited testing of raw materials and production processes. As of early 2026, national accreditation bodies across Europe are actively setting up programmes to accredit CBAM verifiers, coordinated by European Accreditation (EA).
Applies to EU imports of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. From 2026, importers must purchase CBAM certificates based on verified embedded emissions data. Accredited verifiers -- now being credentialed by national accreditation bodies under EA coordination -- will confirm that emissions declarations are accurate and complete.
Key Dates
Compliance Timeline
2023-10-01
Transitional reporting period begins
2025-12-18
Implementing Regulation (EU) 2025/2358 on CRCF certification published
Any EU-based importer of goods covered by CBAM -- cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen -- must report embedded emissions and, from 2026, purchase CBAM certificates. This applies regardless of company size.
What testing is required for CBAM compliance?
Importers need verified data on the embedded emissions of their products. This typically requires chemical composition testing (elemental analysis via ICP-OES, XRF) and emissions factor verification. Testing must be performed by accredited laboratories to ensure data quality.
What happens if I do not comply?
Failure to surrender sufficient CBAM certificates will result in a penalty of EURÂ 100 per tonne of unreported CO2 equivalent, plus the obligation to purchase the missing certificates. Repeated non-compliance may lead to import restrictions.
Do non-EU manufacturers need to act?
Non-EU manufacturers are not directly subject to CBAM, but their EU customers will request verified emissions data. Manufacturers who proactively obtain accredited test reports will have a competitive advantage in the EU market.
What is CBAM verifier accreditation?
CBAM verifiers are independent professionals who confirm that importers' emissions declarations are accurate. The accreditation framework is defined by Delegated Regulation (EU) 2025/2551. In early 2026, European Accreditation (EA) established a dedicated Task Force on EU CBAM and published a directory of national accreditation bodies that are setting up programmes to accredit these verifiers.
EA directory of NABs for CBAM verifier accreditation
How does lab testing support CBAM verification?
Accredited laboratories provide the underlying test data that feeds into CBAM verification. Labs perform chemical composition analysis and emissions factor testing on imported materials. Verifiers then use these accredited test reports to confirm that the embedded emissions declared by importers are correct. Finding a lab with the right accredited test methods is the first step in the compliance chain.
This guide is an educational resource to help you understand testing requirements. It does not constitute legal advice. Always consult the official regulation text and qualified legal counsel for compliance decisions.
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