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CBAM 2026: the freight emissions data your EU importers will ask for

By Mayur Rawte · · 11 min read

The Carbon Border Adjustment Mechanism definitive period began on 1 January 2026. From that date, EU importers of cement, iron and steel, aluminium, fertiliser, electricity, and hydrogen have to buy CBAM certificates against the embedded emissions of every shipment that crosses the border. The freight leg of that calculation — the CO2 emitted moving the goods to the EU customs territory — is part of the embedded total, and it is the part most exporters and their carriers have not yet figured out how to report.

I'm writing this from the methodology side of EcoFreight, so I'll spend most of the post on the freight-emissions piece specifically: what your EU buyer is going to ask you for, how the default-value penalty works after the transition period closed at the end of 2025, and how the calculator output maps onto CBAM reporting fields. If you only have ten minutes, jump to the worked example on a Shanghai-Rotterdam steel shipment — the EUR 1.5M annual number for a mid-size importer is what tends to focus people.

What CBAM actually does

CBAM is the EU's answer to carbon leakage. The idea is straightforward: the EU Emissions Trading System puts a price on CO2 for European producers of carbon-heavy goods, so producers outside the EU have a cost advantage when they export to the EU. CBAM closes that gap by charging EU importers a carbon price on embedded emissions that mirrors the ETS price, with a credit for any carbon price already paid in the country of origin. The legal basis is Regulation (EU) 2023/956 (the CBAM Regulation itself) and the operational rules sit in Implementing Regulation (EU) 2023/1773. The European Commission's CBAM portal at taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en is the canonical source for the legal text and the Commission's Q&A documents. We track our reading of the CBAM treatment against the wider 2026 freight compliance checklist, which is where I'd start if you want the full perimeter (EU ETS, CSRD, IMO CII) before zooming into CBAM.

The transition period ran from 1 October 2023 through 31 December 2025. During that window, importers reported embedded emissions quarterly but did not pay anything — the point was to build the reporting muscle, not collect revenue. As of 1 January 2026 the definitive period applies: importers register as authorised CBAM declarants, declare embedded emissions annually, and surrender CBAM certificates at a price linked to the weekly average EUA auction price. ICAP's compliance-phase summary at icapcarbonaction.com has a useful timeline overview if you want a second source on the dates.

Who is in scope

Six product categories are in scope at the start of the definitive period: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. The Commission has been clear that the list will broaden — plastics, chemicals, and downstream products are on the review docket — but for 2026 the six categories are what matters. The threshold is EUR 150 per shipment: below that, the goods are out of scope. Above it, the importer of record has to register and report.

In practice the importers feeling this first are in steel and aluminium. The embedded emissions per tonne for those products are large — the EU's own default values run roughly 2.0 t CO2e per tonne for hot-rolled flat steel and around 8.0 t CO2e per tonne for primary aluminium — so even modest shipment volumes produce CBAM certificate costs in the hundreds of euros per tonne of product. Cement and fertiliser importers will feel it next, hydrogen and electricity less so for now because the in-scope volumes are smaller. If you're importing finished consumer goods that contain steel or aluminium, you're not in scope this year, but the downstream-product extension is the obvious next move.

What freight data your importer will ask you for

Here is the part that catches carriers and EU exporters off guard. CBAM's embedded-emissions definition includes both direct production emissions and what the Implementing Regulation calls "indirect" emissions — emissions from electricity used in production — and a third category covering transport from the production site to the EU customs border. The freight piece is in there, even though it gets less attention than the production-emissions debate.

For each in-scope shipment, your EU buyer's authorised declarant has to be able to say, in the annual CBAM declaration, how much CO2e was emitted in transit. They will ask you for three things and you should be able to give them all three without doing fresh analysis each quarter:

  1. Per-shipment WTW CO2e for the full transport chain. Well-to-wake, in kilograms or tonnes, covering every leg from the production site to the EU customs frontier. Not tank-to-wake. WTW is what CBAM expects because it is what ISO 14083 expects, and the Commission's Q&A documents lean on ISO 14083 as the reference methodology.
  2. A mode-by-mode breakdown. Ocean, road, rail, inland waterway, air, separately. The auditor wants to see that the long ocean leg and the short road leg into the EU are calculated with the right factors for each mode.
  3. The data quality tier per leg. Primary, secondary, or default, in the ISO 14083 sense. A leg calculated with metered fuel burn on the specific voyage is primary. A leg calculated with a carrier-specific fleet average is secondary. A leg calculated with a GLEC default factor is default. CBAM does not yet require Tier 1 / Tier 2 / Tier 3 labelling explicitly, but the auditor will ask anyway, and being unable to answer is the single thing most likely to get a declaration kicked back for further review.

The good news is that an ISO 14083-compliant carrier report has all three of these fields in it natively. If your carrier hands you a GLEC Declaration that already breaks out WTW per leg and per mode, you have what your buyer needs. If you're still getting a single annual CO2 total in a PDF attached to an invoice, that is the gap you need to close before the 2026 declaration is due (the first definitive-period declaration covers calendar year 2026 and is due by 31 May 2027). The Scope 3 Category 4 CDP guide walks through how the same per-leg data feeds the upstream-transportation disclosure, which is the most common parallel exercise CBAM-exposed importers are running.

Default values versus actual values

Through the transition period CBAM allowed importers to use Commission-published default values for embedded production emissions when they couldn't get verified actuals from the producer. That was a deliberate concession to give exporters time to set up emissions monitoring. From 1 January 2026 the rules tighten: for the direct production-emissions component, importers must use actual values determined by the producer and verified by an accredited verifier. Default values are still permitted as a fallback, but only with a penalty markup applied to make actuals the economically rational choice.

The freight component is treated slightly differently. The Commission allows defaults to remain in use for the transport leg longer than for production emissions, which makes sense given how fragmented transport-chain data still is. But "allowed" does not mean "free." Where an importer reports the freight component using a default factor, the underlying assumption is a high-emissions default — the Commission picks the conservative number on purpose, so that using a default is always more expensive than reporting a verified actual. The point is to push exporters and their carriers to provide real data.

My read on this, and I'll mark it as an opinion rather than a regulatory citation: the freight default is going to look generous in 2026 and stop looking generous in 2027 once the Commission has its first year of actual-data evidence to recalibrate against. If you can supply your buyer with ISO 14083-quality freight numbers this year, do it. Waiting for the rules to bite is the wrong call.

The default-factor penalty: a worked example

A typical mid-size EU steel importer, sourcing hot-rolled flat steel from a Shanghai-area mill and bringing it in through Rotterdam. One shipment is 25 tonnes of steel, moving in a standard 40-foot container. The ocean leg from Shanghai to Rotterdam via the Suez Canal is roughly 19,600 km routed. The GLEC v3.2 default WTW factor for a container ship on this trade lane is around 8.15 g CO2e per tonne-km.

19,600 km × 25 t × 8.15 g/tkm = 3,993,500 g CO2e, or about 3,990 kg CO2e just for the transport leg of one shipment. Round that to 4 tonnes CO2e to keep the arithmetic clean. At an EU ETS-equivalent CBAM certificate price of EUR 75 per tonne of CO2 — the EUA auction price has been hovering in the EUR 70-85 range through early 2026 — that one shipment costs about EUR 300 in CBAM certificate cost on the freight leg alone, before anything to do with the production emissions of the steel itself.

Now scale up. A mid-size importer running 5,000 such shipments a year (which is a credible volume for a 125,000-tonne annual steel import programme): 5,000 × EUR 300 = EUR 1.5 million per year, on the transport-emissions piece of CBAM alone. That number drops if the importer can demonstrate that the actual carrier reported a lower WTW factor — say, a 7.0 g/tkm Tier 2 figure for a modern, well-managed container service — in which case the freight cost falls to roughly EUR 1.29 million. The delta is real money. It also drops to zero if the goods are reclassified out of scope or routed through inward processing relief, but those are edges, not the main path.

One thing I want to flag honestly — this is the gap in my analysis. The exact mechanism for how the Commission will recalibrate the freight-default factor across the rest of the definitive period is not yet published. The Implementing Regulation requires periodic review of the default values, and the first round of revisions could land in late 2026 or early 2027. The EUR 300-per-shipment number above is based on the freight-default treatment as I understand it from the current DG TAXUD Q&A documents, but if the Commission tightens the freight-default factor materially, the penalty on default-reporting could rise sharply. I'll update this post when the next round of guidance is out.

What changes for the EU exporter side

If you're a steel mill in Shanghai or a fertiliser plant in Casablanca, CBAM is technically your EU importer's compliance problem — they are the ones who buy and surrender certificates. In practice, your EU buyer is going to ask you to produce data, and increasingly to have that data verified by an accredited third party, because their CBAM declaration depends on it. Producers who can produce verified emissions data for both the production process and the transport chain will keep CBAM-exposed business; those who can't will lose it to producers who can, or eat the default-penalty cost in their selling price.

The carrier sits in the middle. Whichever mode you operate — ocean, road, rail, or air — your customer's CBAM declaration depends on you being able to produce per-shipment WTW emissions in a form their verifier will accept. That means ISO 14083-aligned methodology, GLEC v3.2 default factors at minimum, and ideally a route to Tier 2 fleet-specific factors for any carrier with a regular EU-bound trade lane.

How EcoFreight responses map to CBAM fields

This is the part most readers of this blog actually care about. The EcoFreight calculator and the API behind it return a per-leg breakdown that lines up with the three CBAM data needs above. Here is how the response fields map across:

  • emissions.wtw → CBAM embedded-transport-emissions value. Total WTW CO2e in kg for the full transport chain, summed across all legs. This is the number that goes into the declaration.
  • emissions.legs[].mode and emissions.legs[].wtw → mode-by-mode breakdown. Ocean, road, rail, inland waterway, air, each leg separately, each with its own WTW figure. This is what the verifier asks for when they want to see that the calculation isn't a single blended factor over a multi-modal route.
  • calculation.emission_factor.source → methodology citation. For EcoFreight this is always "GLEC Framework v3.2 / ISO 14083:2023" because those are the factors the calculator uses. Verifiers expect a clear methodology statement and being able to point at this field is faster than digging through PDFs.
  • calculation.emission_factor.quality → the data quality tier per leg. Values are primary, secondary, or default, mapping directly to ISO 14083 tiers and to the CBAM verifier's expectation of which legs were calculated from real fuel burn versus from defaults.

If your buyer's verifier asks for "the embedded transport emissions, mode-by-mode, with data-quality declaration per leg," those four fields are the answer. The EcoFreight calculator exposes the same numbers in the UI for ad-hoc shipments; the API at /docs is the right way to embed them into ERP or freight-procurement workflows. The full methodology is on the methodology page.

What to do this quarter

Short, ordered, practical. If you are an EU importer of CBAM goods, a producer exporting to the EU, or a carrier whose customers fall into either bucket, here is the list:

  1. Confirm whether you have CBAM declarant status. If you are importing in-scope goods above EUR 150 per shipment and you have not yet registered as an authorised CBAM declarant, that registration must be in place before the first 2026 declaration is due. Without it, your goods cannot clear EU customs.
  2. Inventory your in-scope shipments. Six product categories. List every supplier from outside the EU, every product code that falls into iron and steel, aluminium, cement, fertiliser, hydrogen, or electricity, and every shipment volume for calendar 2026.
  3. Ask each carrier for ISO 14083 / GLEC v3.2-compliant per-shipment WTW reporting. If they can supply it, ask for the data-quality tier per leg. If they cannot, you have a vendor-selection conversation to have before the next contract renewal.
  4. Reconcile production-emissions data with your supplier. The production component, not the freight one, is where most CBAM cost sits for steel and aluminium. Make sure the producer's verified emissions data is in your hands and matches what they have submitted to their own verifier.
  5. Model the default-versus-actual cost delta. For each major import lane, calculate the CBAM certificate cost under default freight factors and under your carrier's actual reported factor. The difference is the business case for switching to a Tier 2 carrier or pushing your existing carrier to provide better data.
  6. Set the internal deadline at end of Q3 2026. Not end of Q1 2027. The first declaration is due 31 May 2027 and you do not want to be scrambling for carrier data in April.
  7. Keep an eye on the downstream-product extension. The Commission's review timetable suggests plastics and chemicals are next. If you import finished goods that embed steel or aluminium and are not in scope today, you may be in scope in 2027 or 2028.

Sources

European Commission CBAM portal: taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en. Regulation (EU) 2023/956 (the CBAM Regulation). Implementing Regulation (EU) 2023/1773 governing reporting obligations during the transition. DG TAXUD CBAM Q&A documents published alongside the Implementing Regulation. ICAP's compliance-phase summary: icapcarbonaction.com/en/news/eu-cbam-enters-compliance-phase-and-outlines-path-ahead. GLEC Framework v3.2 emission factors, Smart Freight Centre, 2023. ISO 14083:2023 — Quantification and reporting of greenhouse gas emissions arising from transport chain operations. EUA auction prices referenced from EEX weekly settlement data. The 8.15 g/tkm container-ship default factor used in the worked example matches the GLEC v3.2 fleet average for that trade lane and is the same factor used in the GLEC v3.2 worked-examples post.

Related: the 2026 freight compliance checklist, which covers EU ETS, CSRD, and IMO CII alongside CBAM and is the right starting point if you are mapping out the full regulatory perimeter. For the underlying calculation methodology, see the GLEC v3.2 worked examples. The EcoFreight calculator will export the per-leg WTW breakdown that lines up directly with the CBAM declaration fields described above.