The Carbon Border Adjustment Mechanism (CBAM) is a key environmental policy adopted by the European Union to address the risk of carbon leakage beyond its borders.

Carbon leakage occurs when production is relocated from the EU to countries with less stringent climate policies, or when EU-produced goods are replaced by more carbon-intensive imports. 

• Importers of goods listed in Annex I to the CBAM Regulation that are released for free circulation in the EU customs territory. These goods include cement, iron and steel, aluminium, fertilisers, hydrogen, and electricity. 
• Operators of installations outside the EU that export these goods to the Union.

From 1st January 2026, importers and indirect customs representatives acting for non-EU importers must be authorised as CBAM declarants.

 And from 2027 onwards, authorised CBAM declarants must submit a CBAM declaration to the European Commission reporting the greenhouse gas emissions embedded in the goods imported into the EU during the previous year.
 
By the same deadline, authorised CBAM declarants must purchase and surrender CBAM certificates corresponding to the embedded emissions declared, at a price aligned with the carbon cost that would have applied had the goods been produced under the EU Emissions Trading System (EU ETS).
 
Where authorised CBAM declarants choose to report actual embedded emissions, rather than the default values from the external installation operators, those emissions must be independently verified. RINA can act as a partner for the verification of these emissions under CBAM.
 
Verification typically includes the following steps: Conducting a strategic analysis and risk assessment, reviewing the calculation of embedded emissions and the monitoring procedure, to assess compliance with the CBAM methodology, conducting a site visit, preparing the verification report and issuing the final verification report and verification opinion.

RINA combines technical competence and practical experience in greenhouse gas verification with several accreditations under EN ISO 14065 and EN ISO/IEC 17029. Together, these competencies and accreditations provide a strong foundation for CBAM-related activities in line with CBAM accreditation criteria.
 
In addition, RINA holds multiple accreditations for the validation and verification of greenhouse gas reduction and removal projects. Although distinct from CBAM verification, these additional competencies and accreditations may also be relevant in CBAM-related contexts, particularly as the European Commission continues to define the rules on carbon price deduction and to assess whether, and to what extent, carbon credits or other offsetting mechanisms from regulated or voluntary markets may be taken into account under the evolving CBAM framework.

Carbon Border Adjustment Mechanism (CBAM) embedded emissions and cost formula

N: Number of CBAM Certificates (t CO2e)
a: specific embedded emissions (actual or default) (t CO2e/t goods)
b: CBAM benchmark (t CO2e/t goods)
f: CBAM reference parameter, defined in Article 10b of Directive 2003/87/EC and incorporated in Implementing Regulation (EU) 2025/2620; for 2026 it is set at 97.5% and then decreases progressively in the following years (e.g. 95% in 2027, 90% in 2028, etc.), until reaching zero when free allowances are completely phased out
C: carbon price already paid (€/t CO2e)
P: price of CBAM Certificates (€/t CO2e)
Q: quantity of goods