CBAM and EU Carbon Compliance Advisory

The EU Carbon Border Adjustment Mechanism moved into its definitive phase on 1 January 2026. Importers of iron and steel, aluminium, cement, fertilisers, hydrogen, and electricity now need authorised declarant status, verified emissions data from their suppliers, and a plan to buy CBAM certificates.

FG Capital Advisors sets up CBAM compliance for EU importers and prepares their non-EU suppliers to report. We charge a fixed fee for the setup and an annual retainer for reporting.

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Industrial plants releasing emissions under a cloudy sky

What Importers Have to Do Now

Authorised Declarant Status

Importers bringing in more than 50 tonnes of covered goods a year must hold authorised CBAM declarant status. Hydrogen and electricity have no threshold. Customs representatives acting for non-EU importers need the status too.

Embedded Emissions Data

Each shipment's direct and indirect emissions must be calculated using installation-level data from the producer. Where real data is missing, default values apply, and they are set to cost more over time.

Certificate Purchases

CBAM certificate sales open on 1 February 2027 for goods imported in 2026. At each quarter end, declarants must hold certificates covering at least 50% of embedded emissions imported so far that year.

Annual Declaration

The first annual declaration and certificate surrender is due by 30 September 2027. It must be backed by emissions data checked by an accredited verifier.

Shipping containers stacked at a busy port
Every covered shipment needs a CBAM record from customs entry to annual declaration.
Industrial harbour with smokestacks
Embedded emissions are measured at the installation that made the goods, not at the EU border.
Shipping containers on a freight train at a port
Importers above 50 tonnes a year need authorised declarant status before they import.
European Union flag flying near a building
Declarations are filed with national competent authorities under EU rules.

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Source: European Commission, Carbon Border Adjustment Mechanism, as amended by the 2025 CBAM simplification regulation.

What We Set Up

  1. Exposure review. We map your imports by CN code, origin, supplier, and volume, check whether the 50-tonne threshold applies, and estimate your certificate cost under default values and under supplier data.
  2. Declarant application. We prepare and file your authorised declarant application with your national competent authority, including the financial guarantee where required.
  3. Supplier data collection. We send templates to your non-EU producers, train their teams on the EU calculation method, and review the installation data they return.
  4. Verification readiness. We get supplier data into shape for accredited verification, so you can use actual emissions instead of default values.
  5. Reporting and certificate planning. Under the annual retainer, we prepare the declaration, track quarterly holding requirements, and plan certificate purchases against your import calendar.

For Non-EU Producers

Steel mills, smelters, cement plants, and fertiliser producers selling into the EU are being asked by their buyers for installation-level emissions data. Producers who cannot provide it force their buyers onto default values, which raises the buyer's CBAM cost and makes the producer harder to buy from.

We work with producers to measure emissions using the CBAM method, document the carbon price already paid in their country, and prepare for verification. That gives their EU customers a lower, defensible CBAM bill.

Industrial complex with smokestacks near the water

Who Leads the Work

Amanda Martins

Leads FG Capital Advisors' carbon markets advisory, covering carbon pricing, compliance schemes, and emissions accounting for corporate clients.

Niavo Ratsimbazafy

Leads emissions quantification, GHG verification readiness under ISO 14064, and monitoring and reporting systems for industrial and project clients.

Fees

The setup is a fixed fee that depends on the number of CN codes, suppliers, and installations. Annual reporting is a separate retainer. Request an estimate with your import volumes and supplier list, and we will reply with the scope and fee.

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FG Capital Advisors provides advisory services and does not act as an accredited CBAM verifier or customs representative. Obligations and penalties are set by EU law and national competent authorities.

Photos via Unsplash by Patrick Hendry, 雙 film, Chris LeBoutillier, Wolfgang Weiser, Christian Lue and Jakub Żerdzicki.