Regulatory Compliance Brief
CBAM Compliance
Statement
Carbon Border Adjustment Mechanism (Reg 2023/956) — Importer obligations from 1 January 2026
1 Jan 2026
Full regime in force
6
Sector groups in scope
>50t/yr
Registration threshold
Chile · Peru · Brazil
LATAM origins in scope
The Carbon Border Adjustment Mechanism requires EU importers of carbon-intensive goods to purchase CBAM certificates corresponding to the embedded carbon in their imports. From 1 January 2026, importers must register as CBAM declarants, report embedded emissions, and surrender certificates annually. CouloirIQ maps your CBAM exposure before shipment and tracks submission readiness throughout the trade lifecycle.
Sectors and goods in scope
| Sector | Key Goods | LATAM Origin | Importer Action |
|---|---|---|---|
| Fertilisers | Urea, ammonium nitrate, nitrogen-based | Brazil · Chile | Embedded N₂O data + certificate |
| Iron & Steel | Billets, flat products, pipes, tubes | Brazil · Argentina | Embedded CO₂ per tonne |
| Aluminium | Primary aluminium, alloys, unwrought | Brazil · Peru | Embedded emissions declaration |
| Cement | Portland cement, clinker, aluminous | Low LATAM volume | Embedded CO₂ per tonne |
| Electricity | Electrical energy | Not applicable | Grid emission factor |
| Hydrogen | Pure hydrogen, hydrogen compounds | Chile (green H₂) | Production pathway emissions |
Implementation timeline
Oct 2023 – Dec 2025
Transitional phase: Quarterly emissions reporting only. No certificate purchase required. Importers must register and submit CBAM reports via the Transitional Registry.
1 Jan 2026
Full regime: CBAM declarant authorisation required. Embedded carbon must be verified. CBAM certificates must be purchased and surrendered annually by 31 May.
31 May annually
Annual surrender: Declarants surrender certificates equal to embedded emissions from prior year imports. Shortfall = penalty of €100 per tonne CO₂ + retroactive purchase obligation.
📊 Example exposure — 500t urea import
Import volume
500 tonnes
Embedded N₂O (typical)
~2.4 tCO₂e / tonne
Total embedded emissions
1,200 tCO₂e
CBAM price (est. €60/t)
€72,000
What CouloirIQ does
✓
CBAM applicability screening — Flags CBAM exposure at corridor check stage, before any commitment is made.
✓
Embedded carbon data collection — Supplier portal requests embedded emissions documentation directly from the exporter.
✓
Registry submission readiness — Checks required fields against the CBAM Transitional Registry schema before you submit.
✓
TwinLog audit trail — Exportable signed PDF of all CBAM compliance actions for auditor or customs presentation.
Check your CBAM exposure before your next shipment
Free corridor check · No account required · Results in under 60 seconds
couloiriq.app/downloads