12 November 2025 – The Commission’s goals for the timely verification of CO2 emissions are extremely ambitious. Not only does it currently lack a network of verifiers, but as of the key date 1 January 2026, emissions data would also have to be collected immediately. In addition, every non-European producer would have to undergo a physical inspection of their production sites – how this is supposed to be achieved by 2027 remains unexplained by the Commission.
CBAM verification could become difficult
The Commission had originally promised simplification with the CBAM carbon border adjustment. However, the recently surfaced draft implementing regulations suggest that things are becoming even more complicated.
According to the Implementing Regulation on the application of the principles for verification of declared embedded emissions, the problem will likely arise that as of 1 January 2026, no accredited verifiers will be available, meaning emissions data cannot yet be collected. Consequently, by the time reports are due in 2027, full-year 2026 data will not be available.
Physical verification visit mandatory
Sounds complicated? It is. On top of that, all companies that wish to have their CO2 emissions verified must undergo an on-site physical inspection in the first year. This means every cement producer, steel mill, aluminium re-roller, and fertilizer manufacturer outside Europe intending to export goods to the European Union must receive a visit from an accredited CBAM verifier.
If no verified data are available, the CBAM default values must be used – which, as of now, do not yet exist.
CO2 price to be published retroactively in 2026
Fortunately, the Commission has at least created the legal basis to publish the CO2 price retroactively through the Implementing Regulation for the calculation and publication of the price of CBAM certificates. This means the price for Q1 2026 will only be published in Q2 2026 – but will still have to be paid in 2027. And all this while CBAM declarants are still unable to calculate their actual costs.
Regulations hastily stitched together
Looking at the various CBAM draft implementing regulations currently circulating – we were able to review today’s draft concerning information communicated by customs authorities – it becomes clear that the Commission is cobbling together these regulations hastily and under immense pressure.
This sheer flood of drafts will inevitably lead to overlooked errors – not only within the Commission but also among the Member States. As already seen in the draft regulation on steel tariffs and import quotas, it also creates the risk that the Commission will quietly appropriate additional powers through the back door – powers it should neither possess nor be granted.
Is the Commission appropriating new powers?
It is also clear why the Commission is doing this: without establishing the missing legal framework, it would lose an entire year – a year in which a majority of MEPs might come to their senses and decide to send CBAM where it truly belongs: the hazardous waste dump.
One can only wonder where Manfred Weber’s loudly proclaimed crowbar has gone!
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