CBAM and EUDR in 2026: What These EU Rules Mean for Your Supply Chain

CBAM (the Carbon Border Adjustment Mechanism) and EUDR (the EU Deforestation Regulation) are two EU rules reshaping how raw materials and agricultural goods are imported in 2026 - but they're moving in opposite directions. CBAM has entered its definitive regime and now carries real financial obligations. EUDR, by contrast, has just been pushed back for the second time. If your supply chain touches metals, fertilisers, timber, coffee, cocoa, rubber, soy or palm oil, it's worth being precise about what applies right now and what's been delayed by another year.

CBAM: the definitive regime has applied since 1 January 2026

According to the European Commission, CBAM's definitive regime became applicable on 1 January 2026, closing out the transitional reporting-only phase that ran from October 2023. For importers of iron, steel, aluminium, cement, fertilisers, electricity and hydrogen, this is no longer paperwork-only reporting - it's a real obligation: measuring the embedded carbon emissions in those goods, registering as an authorised CBAM declarant through the CBAM Registry, and purchasing certificates that match those emissions.

The 50-tonne threshold: who's exempt for now

There's a de minimis threshold that gets overlooked surprisingly often. Per the Commission's own guidance, only importers bringing more than 50 tonnes of CBAM-covered goods into the EU per calendar year - assessed per product - are required to hold authorised declarant status and purchase certificates. Stay below that and your business isn't currently obligated to register or buy certificates, though the threshold is cumulative across the year, so it's worth tracking rather than checking only after the fact. One more planning detail for anyone above the threshold: certificate prices are calculated as a quarterly average in 2026 and switch to a weekly average from 2027, which changes how precisely you can forecast the cost.

A concrete case: a business importing around 30 tonnes of aluminium profile a year sits below the threshold and currently owes nothing under CBAM. If a new contract pushes that to 60 tonnes next year, the obligation kicks in automatically - better to plan for that possibility ahead of time than discover it once the shipment is already at customs.

EUDR: pushed back to 30 December 2026 and 30 June 2027

While CBAM tightens, EUDR has loosened. In December 2025, the European Parliament approved a second postponement of the regulation's application dates. According to the European Parliament and the European Commission's Access2Markets portal, the new dates are: 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small enterprises. The stated reason is to give businesses another year to prepare and to let the Commission finish upgrading the IT system used for filing due diligence statements before it becomes mandatory in full.

The postponement comes bundled with simplifications: micro and small operators sourcing from low-risk countries will be able to file a single simplified declaration in the information system instead of a full due diligence statement, and downstream operators no longer have to file their own declarations - registering in the system and citing the reference number from the upstream declaration is enough. The underlying traceability requirement hasn't gone away: timber, coffee, cocoa, rubber, soy and palm oil still have to be demonstrably free of deforestation that occurred after 31 December 2020 - what's changed is how the paperwork gets filed, not the substance of the obligation.

What this means for your business right now

• Check your annual import volume against CBAM-covered products. If you're over 50 tonnes on any single product, declarant registration and certificate purchases are already relevant this year, not a future problem.
• Don't relax just because EUDR moved. A year isn't forever - 30 December 2026 will arrive faster than it feels, especially with multiple suppliers across different countries.
• Ask suppliers for traceability data early - origin, plot-level geolocation, emissions certificates - rather than in the final quarter before the deadline.
• Confirm your position in the chain. If you're a downstream operator, ask your supplier whether they've filed and for the reference number - it may save you a separate filing.
• Get advice specific to your case. Thresholds, product codes and country-risk classifications are worth checking with a customs or environmental compliance specialist rather than relying on a general article.

Where transport fits into all of this

Neither emissions calculations nor origin traceability are a transport service in themselves, but how your logistics chain is organised affects how cleanly that paperwork reaches customs. Consolidating shipments with clear, consistent data per batch makes it easier to reconcile CBAM or EUDR declarations against the actual cargo, and working with a carrier who knows the route and the current rules reduces the risk of delays from mismatched documentation - the same kind of mismatch that most often holds cargo up at EU customs.

If your business is untangling duties, VAT and new environmental declarations at the same time, it's worth getting the whole documentation chain in order together: see our breakdown of who pays customs duties and VAT depending on the Incoterm, and our step-by-step guide to EU customs clearance for a first import. If shifting tariffs and regulatory deadlines mean you need to change routes or suppliers quickly, our flexible EU freight transport is built for exactly that.

Sources: European Commission - CBAM definitive regime; Access2Markets - EUDR postponement.

If your business imports raw materials or agricultural products into the EU, start preparing your CBAM and EUDR documentation now rather than waiting for the deadline to get close.