Polish importers are entering the financial phase of the EU Carbon Border Adjustment Mechanism. From 1 February 2027, authorised CBAM declarants will be able to purchase certificates covering emissions embedded in goods imported during 2026. For companies exposed to steel, aluminium, cement, fertilisers, electricity and hydrogen imports, CBAM is therefore becoming a budgeting and cash-flow issue rather than primarily a reporting exercise.
The definitive CBAM regime has applied since 1 January 2026. Under the current framework, importers above the 50-tonne annual threshold for the main mass-based CBAM sectors generally need authorised declarant status. They must calculate embedded emissions and ultimately surrender certificates corresponding to the carbon liability associated with their imports.
First certificates will be sold in February 2027
The European Commission confirms that CBAM certificates for 2026 imports will become available for purchase from February 2027. Their price is linked to EU Emissions Trading System allowance prices. In 2026 the certificate price is calculated using a quarterly average, while from 2027 the reference will move to a weekly average.
The first annual CBAM declaration, covering imports made in 2026, must be submitted by 30 September 2027. By the same deadline, importers will have to surrender the corresponding certificates. This means companies need to estimate their exposure well before the formal annual settlement date.
Polish companies need better emissions data
The financial impact will depend not only on import volumes but also on the quality of emissions information received from non-EU suppliers. Importers can use actual embedded-emissions data where the required verification conditions are met. Otherwise, default values published by the European Commission may apply.
This makes cooperation with suppliers increasingly important. Procurement, customs and sustainability teams need consistent information about tariff classifications, countries of origin, production installations and embedded emissions. The CBAM Registry is becoming the central platform through which declarants manage authorisations, emissions information and reporting obligations.
CBAM turns carbon into an import cost
The mechanism is designed to narrow the carbon-cost difference between EU production covered by the ETS and imports from countries with less stringent carbon pricing. If a carbon price has already been effectively paid in the country of production, the corresponding amount can be taken into account when determining the CBAM obligation.
For Polish importers, the practical challenge is increasingly financial. Businesses need to incorporate expected certificate purchases into budgets, improve forecasts of imported volumes and verify whether suppliers can provide reliable emissions data. The cost will also evolve as the phase-out of free EU ETS allowances progresses.
2027 will be the first major settlement year
Companies should use the remaining months of 2026 to test their CBAM data flows and estimate potential certificate requirements. The European Commission has also been publishing new guidance on verification and accreditation, with the first accredited CBAM verifiers expected to become available around September 2026.
For businesses with significant exposure to covered imports, CBAM will increasingly influence sourcing decisions, supplier negotiations and working-capital planning. The transition from reporting to a real carbon-linked import cost is already under way.
Sources: European Commission – CBAM definitive regime, CBAM Registry and verification guidance; Polish KOBiZE guidance and updates.
