CBAM 2026: What the Carbon Border Adjustment Mechanism Means for Importers in Finland

CBAM 2026: What the Carbon Border Adjustment Mechanism Means for Importers in Finland

Summary: CBAM (the Carbon Border Adjustment Mechanism) changes the compliance landscape for imports into the EU from 2026 onwards. This Insight explains who is affected, the key dates, what importers must do and when, and how CBAM impacts costs and supply chains.

From a business perspective, CBAM is not “just another report”. It is a regulatory framework that ties customs classification, emissions data and financial obligations into one compliance workflow. For many companies importing into Finland, CBAM will become a practical question of risk management, budgeting and contract allocation.

If you need support assessing your CBAM exposure and building a practical compliance approach, see our service: International Trade & Sanctions.

1) Who does CBAM apply to?

CBAM applies to companies that import certain goods from outside the EU into the EU customs territory (e.g., into Finland), typically when goods are released for free circulation. In practice, the obligations attach to the party acting as the importer of record (i.e., the entity on whose behalf the import declaration is made).

CBAM currently covers selected carbon-intensive sectors (including, for example, iron and steel, aluminium, cement, fertilisers, hydrogen and electricity). The scope is determined by CN/HS codes, which means that correct customs classification is critical for determining whether CBAM applies.

De minimis threshold (50 tonnes)

CBAM rules were simplified in 2025 by introducing a mass-based de minimis threshold (initially 50 tonnes per importer per calendar year) for certain sectors. If an importer remains below the threshold in a given year, CBAM obligations may not apply for that year. This is particularly relevant for smaller or occasional importers.

2) What is CBAM, in plain business terms?

CBAM is designed to address the risk of carbon leakage by linking imports to a carbon cost comparable to the EU Emissions Trading System (ETS). It focuses on the embedded emissions of covered goods imported into the EU.

In practical terms, CBAM creates two core deliverables for importers:

• Data: collect product-level emissions information (typically from suppliers/manufacturers) and report it in the required format.
• Cost: from 2026, manage CBAM certificates and related financial exposure as part of import budgeting and pricing.

3) Key dates: what needs to be done, and when?

4) Cost impact: what will CBAM cost in practice?

CBAM certificates are linked to the EU ETS price

The CBAM certificate price is designed to reflect EU ETS allowance prices. Practically, this turns embedded emissions into a budget line that affects landed cost, pricing and margin management.

Default values: if supplier data is not reliable

Where verified product-specific emissions data is not available (or not usable), CBAM allows the use of default values under specific rules. Default values are set conservatively and may materially increase the cost outcome compared to verified actual emissions.

5) Enforcement risk and sanctions: why CBAM is a “customs-risk” topic

CBAM is enforceable. Non-compliance (late or missing reporting, inaccurate data, inadequate documentation, or failures related to certificates) can lead to administrative consequences and financial penalties. It can also impact a company’s broader customs risk profile and disrupt logistics.

The key management message: treat CBAM as a compliance project with ownership, controls and a documented audit trail—similar to other high-impact customs and trade controls.

6) Does CBAM change HS/CN classification or tariff headings?

CBAM does not change HS/CN codes. However, it makes correct classification far more critical, because CBAM scope is determined by CN/HS codes. Misclassification can trigger incorrect CBAM treatment (including under-reporting or missed obligations).

7) Practical next steps: how to prepare (a clear roadmap)

1. Scope mapping: identify imported products and confirm CN/HS codes (including borderline products).
2. Threshold check: assess annual import volumes and whether the de minimis threshold may apply.
3. Data readiness: secure emissions data flows from suppliers and define internal controls and evidence requirements.
4. Cost modelling: estimate the cost effect (certificate exposure + default value risk) and integrate it into pricing/budgeting.
5. Contract allocation: update procurement terms: who provides data, who bears cost changes, and what happens if data is missing or wrong.
6. Governance: assign ownership across procurement, finance, logistics and legal; build a yearly compliance calendar.

If you want a pragmatic start, we can deliver a short CBAM readiness review (scope + classification + process + contract checklist) and a management-ready action plan. For disputes and risk management perspectives in trade-related matters, you can also consult Oscari Seppälä.

Frequently asked questions (CBAM)

Does CBAM affect occasional importers?

Potentially yes, if the goods fall within CBAM scope. However, the 2025 simplification introduced a de minimis threshold (initially 50 tonnes/year for certain sectors), which may exempt smaller annual import volumes in a given year.

Do we need to change HS/CN codes because of CBAM?

No. But classification accuracy is more important than ever, because CBAM applicability is determined by CN/HS codes.

What is the main cost driver from 2026 onwards?

CBAM certificates linked to EU ETS pricing, combined with the risk of default values where verified emissions data is not available or usable.

What should management do first?

Start with a scope and classification check, then confirm data readiness and model the cost impact. From there, align procurement contracts and assign governance and responsibilities.

Need practical CBAM support?

CBAM is best handled like any other business-critical compliance change: confirm scope, build a process, secure supplier data and model financial exposure. We assist importers and trading companies with practical trade compliance and risk management: International Trade & Sanctions.

Responsible lawyers: Liene Krumina and Oscari Seppälä.