The European Commission has issued ten guidance documents for CBAM’s definitive period, including dedicated sector guides for iron and steel and for aluminium. The practical thrust is the shift away from the default emission values relied on during the transitional phase and towards actual verified emissions data obtained from non-EU producers — which is where the cost sits.
What Happened
On 14 August 2026 the Commission published ten guidance documents supporting the Carbon Border Adjustment Mechanism now that the definitive regime has begun. Four general guides cover CBAM concepts, roles and deadlines, a quick reference for non-EU operators, methods for calculating embedded emissions, and calculation of the free-allocation adjustment that reduces the number of CBAM certificates to be surrendered. Six sector guides cover cement, hydrogen, fertilisers, iron and steel, aluminium and electricity, each with worked examples. For automotive the iron and steel and aluminium guides are the material ones, since both are core vehicle input materials. The guidance is non-binding but it is the clearest statement so far of what data must be collected and passed down the chain.
What’s New
- First consolidated Commission guidance written for the definitive regime rather than the 2023-2025 transitional reporting phase.
- Four general guides: CBAM concepts and the compliance cycle; a quick guide for non-EU operators; calculation of embedded emissions; and calculation of the free-allocation adjustment.
- Six sector guides (5a to 5f) covering cement, hydrogen, fertilisers, iron and steel, aluminium and electricity, each with worked examples.
- The iron and steel and aluminium guides set out precisely which production-process data non-EU mills must supply.
- Direction of travel is explicit: default emission values give way to actual verified emissions from the producing installation.
- Aimed at authorised CBAM declarants, non-EU installation operators and verifiers.
Key Dates & Timeline
CBAM definitive period begins
Ten guidance documents published
First CBAM declaration for 2026 imports, with certificate surrender under the definitive regime
Affected Industries
Light duty vehicles · Heavy duty vehicles · Automotive components · Fasteners and formed metal parts · Metals producers · Customs and trade compliance
Who Is Affected
EU-based automotive manufacturers and Tier 1 suppliers importing CBAM-covered steel and aluminium goods; importers of record and authorised CBAM declarants; non-EU suppliers who must provide production-process data; verifiers.
Standards / Products in Scope
CBAM-covered iron, steel and aluminium goods imported into the EU above the applicable de minimis threshold, plus cement, hydrogen, fertilisers and electricity. Goods outside CBAM Annex I are unaffected, and the guidance itself is non-binding.
Prohibitions, Restrictions & Requirements
No new restriction. The obligation is to declare embedded emissions and surrender certificates for covered imports. The guidance clarifies how actual emissions must be calculated and verified rather than creating a new duty.
What Companies Should Do
- Use the iron and steel and aluminium sector guides to identify exactly which production-process data your non-EU mills must supply, then check contractually whether they are obliged to provide it.
- Prioritise your highest-volume steel and aluminium flows for actual-data collection first — the gap between default values and verified actual emissions is where the cost sits.
- Confirm your CBAM declarant or customs agent has an accredited verifier engaged, and build verification lead time into 2027 declaration planning.
- Read the free-allocation adjustment guide before modelling certificate costs; it materially changes the number of certificates to surrender.
Default values were a transitional convenience and they are usually expensive. These guides tell you what to ask non-EU mills for, and the constraint is commercial rather than technical: whether your supply agreements entitle you to the data at all. That is a contracting question to open now, not at declaration time.
Reach out to our regulation experts on chemical and product regulatory compliances