For three years the EU's Carbon Border Adjustment Mechanism was a paperwork exercise — importers reported the carbon embedded in what they bought and paid nothing. That ended. Since January 2026 CBAM is in its definitive phase, and the report has become a bill. For anyone shipping aluminium, steel or cement into Europe from Vietnam, it is now a line in the landed cost, and an unusual one: the number is set less by your price than by your paperwork.

What actually changed in 2026

Under the definitive regime, an EU importer of a covered good must buy and surrender CBAM certificates for the emissions embedded in it — no longer just declare them. The covered goods are steel, aluminium, cement, fertilisers, hydrogen and electricity. Certificates are priced to track the EU Emissions Trading System: the European Commission's official Q2 2026 price was €75.28 per tonne of CO₂e, and non-compliance carries a €100-per-tonne penalty. This sits on top of ordinary customs duty — and, for Vietnamese origin under the EVFTA, that duty is often zero, which paradoxically makes CBAM the larger border cost on some lines.

Why this is an exporter's data problem, not just an importer's tax

Here is the part that reframes it for a Vietnamese factory. CBAM is charged on embedded emissions, and how those emissions are established decides the bill. If the producer supplies verified, installation- and product-specific emissions data, the importer pays for the real carbon. If it doesn't, the EU applies a default value — deliberately conservative, i.e. high — and the buyer pays for the data you failed to provide.

So the commercial logic inverts the usual sustainability conversation. A low-carbon Vietnamese producer that can prove it now lands cheaper at the EU border than a dirtier competitor — and even a middling-carbon producer with clean, verified data beats a clean producer with vague data. Emissions reporting has become a pricing input. This is the same discipline our EUDR brief described for wood, pointed at a different molecule: Europe increasingly buys the documented product, not just the product.

Which of our groups this touches

Two of the six sourcing groups sit in or under CBAM's scope:

  • Aluminium & glass systems. Aluminium is a named CBAM good, and it is a carbon-intensive one — smelting is where the emissions live. For EU curtain wall and window packages, the embedded-emissions figure of the extrusion supplier is now a real cost variable, not a footnote. Our aluminium & glass data note has the market backdrop.
  • Cement — as an input. Cement itself is a covered good, and Vietnam is a major, over-supplied producer (a story in its own right). For our own fiber-cement line, the cement content matters to the embedded-emissions picture of boards shipped into Europe — one more reason the data trail has to start at the input, not the invoice.

The other four groups are outside CBAM today, but the Commission has floated scope expansion to downstream products — worth watching, not yet worth pricing.

What a buyer should do now

For an EU-bound project, treat the emissions data as part of the specification, the way you already treat a fire classification or a certificate of origin. Ask the supplier — or the desk acting for you — for the product-specific carbon figure and its verification, not a generic sustainability statement. On our side, that means flagging CBAM exposure on the aluminium (and cement-content) lines of an EU proposal and pricing the certificate cost in, rather than letting it surface as a surprise at the border.

Sources & data notes

CBAM's move to a definitive, financially binding phase from 1 January 2026; coverage of steel, aluminium, cement, fertilisers, hydrogen and electricity; the certificate-purchase-and-surrender obligation; the official Q2 2026 price of €75.28/tCO₂e; the €100/tonne penalty; the role of verified vs default emissions values; and the proposed downstream scope expansion are drawn from 2025–2026 EU Commission publications and trade-policy analysis. CBAM certificate prices move quarterly with the EU ETS, and scope, methodology and free-allocation phase-out are still evolving. Figures are indicative and for orientation only; confirm the current price, scope and your product's treatment with the official EU texts or qualified counsel before relying on them. This is not legal, tax or customs advice.

Shipping aluminium — or cement-based products — into the EU and unsure what CBAM adds? Send us one BOM and the in-scope lines come back with their carbon-cost exposure flagged and the emissions-data position accounted for, within 48 hours. Our own fiber-cement line, DURAGREEN®, is sourced under the same data discipline.