CBAM finally has its effect felt in retail trade too

This article is available for reading in Trade magazin 2026/04

They summarised what changes in practice from 2026. It would be easy to dismiss CBAM as a problem for industrial importers, but in retail its relevance comes from two directions. One is direct involvement: when a commercial operator acts as an importer in practice and a CBAM-liable product enters the process. The other direction is indirect involvement, which is undoubtedly more common in the retail world: CBAM costs and the necessary data requirements are passed on through the supply chain.

Caution is required even below 50 tonnes

One of the most important messages of the changes made at the end of 2025 is the 50-tonne net weight threshold: those who don’t reach this quantity of CBAM-liable products in a calendar year may be exempt from a significant part of their obligations. This is an administrative relief, but there were still deadlines to meet at the end of 2025. The threshold is risky in retail precisely because it can give a false sense of security: it must be calculated on a calendar year basis, tracking the imports concerned on a net weight basis, and surprises often come from project and investment items.

CBAM will take full effect from 2026: the carbon cost linked to imports will most commonly appear in retail through capital expenditure purchases and across the supplier chain – making customs procedures, data reporting, and cost planning increasingly operational business matters

The practical minimum is therefore simple monitoring and the designation of a responsible person, so that it is apparent in time if the threshold is approached or exceeded due to an atypical import. CBAM becomes really crucial in retail where day-to-day operations actually take place: in customs procedures. In practice the customs tariff number and TARIC supplementary codes indicate the legal basis and status of the import – for instance with a CBAM permit, a de minimis (under 50 tonnes) exemption or a permit application that has already been submitted but is still pending.

CBAM is becoming a data-driven requirement within the supply chain: emission information and certificates linked to imports are increasingly appearing in procurement conditions, contractual responsibility clauses, and even in pricing

Default or real data?

When it comes to CBAM compliance, the risk can be measured in money, but in retail the most painful consequence is often not the penalty itself. Compliance errors can snowball and if regulatory controls are tightened, this can influence import scheduling, release for free circulation and supply continuity. A risk signal or all kinds of questions afterwards quickly become an “operational problem” in retail: delays, extra trips, extra resources in logistics and finance. Meanwhile on the cost side there is the “default” trap. Many players would instinctively choose the easiest route: if there is no manufacturer data, they would calculate using default emission values. However, these can also mean high costs in the new cycle, achieving the opposite of what the company hopes for – they don’t simplify compliance, but make it more expensive. In 2026 CBAM will typically require not a new team in retail, but new control points: in the procurement-customs-finance triangle. CBAM can be managed in the sector if it isn’t a separate “green project”, but is integrated into procurement and customs operations.