CBAM

CBAM (Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956) puts a carbon price on the embedded emissions of certain goods imported into the EU, so that they carry the same carbon cost as goods produced under the EU Emissions Trading System. A transitional reporting period ran from 1 October 2023 to 31 December 2025; the definitive period began on 1 January 2026.

Goods covered (Annex I): cement, iron and steel, aluminum, fertilizers, hydrogen and electricity, with some precursors and downstream products. Fresh fruit, vegetables and food products are not covered. In December 2025 the Commission proposed adding more downstream steel and aluminum products; that proposal is not law yet.

Who does what since 2026:

• The EU importer, as authorized CBAM declarant, declares the embedded emissions of its imports once a year (first by 30 September 2027, for 2026 imports) and surrenders CBAM certificates, on sale from 1 February 2027. An importer of 50 tonnes or less of CBAM goods a year is exempt, except for electricity and hydrogen.
• The producer outside the EU, for example an Egyptian fertilizer or steel plant, supplies installation-level emissions data. Actual data can be used only after verification by an accredited CBAM verifier; otherwise the importer applies EU default values, marked up by 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilizers).

FoodGate Audit helps Egyptian producers of CBAM goods prepare the monitoring plan, calculations and emissions report their EU importers need, ready for the accredited verifier. FoodGate Audit is not a CBAM verifier.

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