SCRM Supplier Compliance & Risk Management

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Regulation (EU) 2023/956 · definitive phase since 1 January 2026

CBAM asks for a number only your supplier knows.

Neither customs nor the importer knows how much CO₂ sits in a tonne of steel. The plant that made it does. That figure has to travel the whole chain – with evidence attached.

The Carbon Border Adjustment Mechanism covers imports of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity into the EU. Since 1 January 2026 the definitive phase applies: importers above the threshold need authorised CBAM declarant status, report embedded emissions and cover them with certificates.

The Omnibus simplifications cut the number of affected importers sharply – below 50 tonnes of CBAM goods per year you are fully exempt. For suppliers little changes: whoever crosses the threshold needs producer data, and that comes from the chain.

Who is affected

  • Importers into the EU above 50 tonnes of CBAM goods per calendar year; the threshold does not apply to electricity and hydrogen.
  • Swiss and Liechtenstein producers shipping steel, aluminium or cement products into the EU – through their customer’s data request.
  • Traders and processors whose upstream suppliers produce outside the EU.
  • In effect every procurement function: large importers pass the carbon cost on, which changes price comparisons.

What has to be done

Exposure
Check annual import volume per CN code. The threshold is cumulative per importer, not per shipment.
Authorisation
Apply for authorised CBAM declarant status before importing.
Emissions data
Collect actual embedded emissions per good and installation – default values are only usable to a limited extent.
Supplier declarations
Obtain producer data on record, referenced to the installation and period.
Declaration and certificates
Annual declaration for 2026 imports in the following year, certificate purchase from February 2027.

How SCRM covers it

Supplier, plant, commodity group

Emissions data belongs to the producing installation, not the trading company – SCRM keeps them apart.

Data requests with deadlines

Request declarations digitally, see what is still outstanding.

Validity per period

Emission values age. Every figure carries a period and a source.

Evidence for verification

Who reported what and when stays traceable – the declaration is subject to checks.

Frequently asked

We are a Swiss producer. Does CBAM affect us?

Not as an obligated party – the duty sits with the EU importer. Very much as a data source: your EU customer cannot file without your installation data. Supplying it quickly and credibly keeps you in the running.

Are default values enough?

They are a fallback and usually less favourable than real figures. Producers who can evidence actual emissions normally pay less.

What happens above 50 tonnes?

The duty applies to the entire calendar year, not from the shipment that crossed the line. So the volume needs watching continuously, not in December.

As of July 2026, following the Omnibus amendments. Not legal advice.

Contact

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