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Mastering EU CBAM: The Three Pillars of Success

By Arne Mielken | Customs Manager Ltd.


CBAM - The Definite Period in Coming! Here are the Three Pillars of CBAM Success, every affected company needs to master

Black text "CBAM Compliance" on yellow industrial backdrop. Words: "UNDERSTAND COMMUNICATE REPORT." Logo: "CUSTOMS MANAGER."
Mastering CBAM: Compliance Essentials - Understand, Communicate, Report for Success in the Definite Period.

The EU’s Carbon Border Adjustment Mechanism (CBAM) is no longer just a buzzword — it’s a compliance reality. With the transitional phase ending, companies importing CBAM goods into the EU must be prepared not only to understand the regulation but also to implement it effectively across their supply chains.


What Is CBAM, and Why Does It Matter for Global Trade?


CBAM is a transformative climate regulation introduced by the European Union to level the playing field in international trade. Its primary goal is to put a fair price on carbon emissions embedded in certain imported goods, ensuring that producers outside the EU are held to similar environmental standards as those within the bloc.


By aligning imported goods with the EU Emissions Trading System (ETS), CBAM helps prevent carbon leakage—the risk that production shifts to countries with weaker climate regulations. In essence, CBAM ensures that the EU's climate goals are not undermined by offshoring emissions-intensive production.


CBAM affects a wide range of stakeholders:


  • Non-EU suppliers must calculate and report embedded CO₂ emissions.

  • EU importers and indirect representatives must collect this data, submit CBAM reports, and—starting in 2026—purchase CBAM certificates.


What Are CBAM Goods?


CBAM currently applies to selected carbon-intensive goods across the following sectors:

  • Iron and Steel

  • Aluminium

  • Fertilisers

  • Cement

  • Hydrogen

  • Electricity (in certain cases)


⚠️ Important: The European Commission has indicated that more goods—including chemicals and polymers—could be added in future phases, so staying ahead of updates is essential. Please subscribe to our Trade intelligence update service where we keep you up to date on all matters CBAM: www.customsmanager.info


CBAM Timeline: When Does What Happen?


  • October 2023 – December 2025: Transitional Phase: EU importers must submit quarterly CBAM reports detailing embedded emissions in imported goods. However, no payments are required during this phase.


  • From January 2026: Definitive Phase: Importers will need to purchase CBAM certificates to match the embedded emissions in their imported goods. Non-compliance will trigger penalties.


What Must CBAM Importers and Their Suppliers Do?


Non-EU Suppliers

  • Must calculate and verify CO₂ emissions for exported goods.

  • Must provide accurate, complete, and timely data using EU-recognised methodologies.

  • Should collaborate closely with importers to ensure seamless data flow and compliance.


EU Importers & Indirect Representatives

  • Must identify CBA-regulated goods in their supply chains.

  • Must collect emissions data from non-EU suppliers.

  • Must submit quarterly CBAM reports via the CBAM Transitional Registry.

  • Must prepare to purchase CBAM certificates starting in 2026.


What are the THREE PILLARS of CBAM Success?


From our experience advising clients across the US, EU, UK and worldwide for the last three years, I’ve found that success with CBAM rests on mastering three key pillars:


Yellow background with industrial imagery. Text: "3 Pillars Of CBAM Success" - Understand, Communicate, Report. Icons: magnifying glass, megaphone, paper.
The "3 Pillars of CBAM Success" include understanding, communicating, and reporting CO2e emissions data. Join our workshops to learn how.

Let's explore:


1. Understand


The first pillar of CBAM success is understanding. Before you can comply, you must understand. CBAM is complex, and there’s no shortcut to building a solid foundation of knowledge.


This involves gaining a deep knowledge of the change process, the individuals involved, and the desired outcomes. It's about comprehending the reasons behind the change, the benefits it will bring, and the potential challenges that may arise. Understanding also means recognizing the different stages of change and knowing how to navigate through them effectively.


You must grasp:

  • What CBAM is trying to achieve (climate protection through fair carbon pricing) and what that means for your company

  • Get clarity on who has to do what and how.

  • How it affects your imports of goods like iron, steel, cement, fertilisers, and aluminium

  • Which deadlines matter, and which data must be collected.

To help you build this fundamental awareness, we offer the EU CBAM Fundamentals Training – a comprehensive 4-hour live online course, running regularly every month. It’s also available on-demand, so you can download and start learning instantly. Browse our events here ad search for "EU CBAM Fundamentals Training"

Need just the essentials? Try our 1-hour on-demand CBAM webinar, including slides, recording and documentation – perfect for busy professionals who require a fast yet informative overview. Access the HERE.


2. Communicate


Communication is a vital component of successful change management. For CBAM, we require effective supplier communication You can’t file an accurate CBAM report without reliable CO₂e data from your non-EU suppliers. That’s where many companies struggle.  It's not just about disseminating information, but also about listening and engaging in meaningful dialogue. Clear, consistent, and transparent communication helps to build trust, reduce uncertainty, and foster a sense of ownership among all stakeholders.


So it's not about sending a request for emission data – it’s about building trust, educating your suppliers, and communicating clearly what you need, why you need it, and by when.


Actions you may need to consider include:


  • Deliver a CBAM workshops to suppliers

  • Communicate CBAM requirements clearly in e-mails, letters and on the phone etc.

  • Counter common objections from suppliers regarding CBAM.

  • Modify contracts to include CBAM requirements using suggested legal language.

  • Create a centralised hub for suppliers to access CBAM-related information.

  • Design a CBAM helpline to offer expert assistance to suppliers without affecting your operations.


Most importantly, however, you may need to explain the EU CBAM Excel template to suppliers and guide them through its completion step by step and advise suppliers on how to accurately measure carbon emissions and understand the methods yourself.

That’s why we created the Effective CBAM Supplier Communication Workshop – a 4-hour, hands-on online session designed to help you:

  • Build a structured outreach strategy

  • Create communication templates

  • Align internal and external messaging

This is not theory – it’s practical and results-driven, focused on helping you get the data you need to file. Search for it here: https://www.customsmanager.org/events

3. Report


The final pillar is reporting. Even with the right data, filing the CBAM report correctly with the EU Commission can be daunting. What format is accepted? Who is responsible? What if you miss a deadline or make an error?


Our CBAM Report Filing Workshop is designed specifically for EU importers and their indirect representatives or agents. In this 4-hour virtual session, we guide you step-by-step through:


These Three Steps Go Hand in Hand

You can’t file without supplier data. You won’t get supplier data without proper awareness and communication. And you won’t even know what to ask if you don’t understand CBAM to begin with. That’s why we’ve created a three-part training journey that’s practical, relevant, and tailored to your needs.


All trainings are offered virtually, run monthly, and can be delivered in-house for companies seeking tailored sessions for their teams.


Flexible Training Formats to Suit Every Need

All our CBAM trainings are:

  • Delivered virtually

  • Available monthly

  • Can be customised and delivered in-house for your team

  • Supported with materials, templates, and expert Q&A


Ready to Master CBAM?

Whether you're an EU importer, an indirect representative, or a non-EU supplier, understanding and acting on CBAM today is key to long-term success. Our training programmes are virtual, flexible, and available monthly—or fully customisable for in-house sessions.


✅ Stay compliant✅ Communicate effectively✅ File accurately✅ Avoid penalties


👉 Visit our EVENTS page and our ON-DEMAND page to browse our CBAM courses, book your CBAM training today or download CBA on-demand content.Visit www.customsmanager.org to book an "expert call" to discuss a private company CBAM workshop.


Let’s make CBAM compliance less complicated — and a lot more manageable.



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