CBAM and Logistics Companies 2026: How Carbon Border Adjustment Affects Supply Chains
Logistics providers are not the importer of record under CBAM — but they are becoming the critical bottleneck for carbon data that their clients urgently need. Since 1 October 2023, the transitional phase of Regulation (EU) 2023/956 has been in force. From 1 January 2026, the definitive regime applies: importers of steel, cement, aluminium, fertilisers, hydrogen and electricity must surrender CBAM certificates or face fines up to three times the certificate price. None of that works without embedded carbon data that only the logistics and freight chain can systematically collect.
- Legal basis: Regulation (EU) 2023/956, Articles 3–11 (scope) and Articles 17–27 (obligations)
- Transitional phase: 1 Oct 2023 – 31 Dec 2025 (reporting only, no certificate purchase)
- Definitive phase: From 1 Jan 2026 (certificate purchase mandatory)
- Logistics role: Indirect — must provide Bill of Lading data, CN codes, production country and embedded carbon certificates from non-EU producers
- Risk: Clients can cancel freight contracts if CBAM data is missing at customs clearance
What CBAM actually is — and what it is not
The Carbon Border Adjustment Mechanism is a carbon pricing tool grafted onto EU customs law. Its purpose is simple: if a tonne of steel produced outside the EU emits carbon that would carry a cost under the EU Emissions Trading System (EU ETS) if produced inside the EU, then the importer pays the equivalent charge at the border.
What CBAM is not is a tariff or a trade restriction in the traditional sense. It does not discriminate by country of origin per se — it discriminates by embedded carbon intensity. A Turkish steel mill with verified low-carbon processes can qualify for a reduced certificate obligation. A German-owned facility outside the EU is not exempt just because the parent is European.
For logistics companies, the crucial legal distinction sits in Article 3(1) of Regulation (EU) 2023/956, which defines the "authorised CBAM declarant" as the importer — not the freight forwarder, not the 3PL, not the shipping line. Yet Article 35 creates an indirect obligation by requiring the declarant to use actual embedded emission values from the producer, communicated through what the regulation calls "the default values" structure. Those actual values can only come through the logistics and customs chain.
The four CBAM sectors that dominate freight volumes
Six product categories are in scope under Annex I of the Regulation. Four of them account for the bulk of bulk and break-bulk freight moving into the EU:
| Sector | CN Codes (examples) | EU imports 2024 (€bn) | Avg. embedded CO₂ (t/t product) |
|---|---|---|---|
| Steel & iron | 7206–7229, 7301–7307 | €38.4bn | 1.85 t CO₂e/t |
| Cement & clinker | 2523, 6810 | €2.1bn | 0.83 t CO₂e/t |
| Aluminium | 7601–7616 (selected) | €12.7bn | 11.5 t CO₂e/t (primary) |
| Fertilisers (nitrogen-based) | 3102, 3105 (N compounds) | €5.9bn | 1.6–4.2 t CO₂e/t |
Sources: Eurostat Comext, 2024 trade data; IPCC default emission factors; JRC CBAM background report 2022.
The liability chain: who is responsible for what
CBAM creates a tiered obligation chain that logistics companies must understand precisely — because being at the wrong tier when a declaration is challenged can trigger contractual liability even when CBAM itself does not directly penalise the freight provider.
The practical implication: a 3PL that fails to collect producer declarations loses a client's ability to use actual emission values, forcing fallback to default values that are deliberately set high (typically 30–40% above average sector emissions) to incentivise primary data collection. That cost difference gets passed back to the 3PL via service-level penalty clauses increasingly inserted into logistics contracts.