90 Days Left: What's Changing?
January 1, 2026 marks the transition from CBAM's transitional to definitive phase. From this date, EU importers will be required to purchase CBAM certificates corresponding to embedded emissions. The reporting-only obligation of the transitional period gives way to financial obligations (Regulation 2023/956, Article 7).
This guide provides an action plan for exporters and importers to make the most of their final 90 days.
Weeks 1-2: Situation Assessment
The first two weeks are about honest self-assessment. Where are you today, and where do you need to be by January 1?
Identify Data Gaps
Evaluate your transitional period reporting experience critically:
- For which products can you provide actual facility data?
- How dependent are you on default values? (Usage will be very limited in the definitive phase)
- Are indirect emissions being calculated correctly?
- Are precursor emissions included?
Understand Verification Requirements
In the definitive phase, embedded emissions data must be verified by accredited verifiers. Start the verifier selection and contracting process now (Commission Implementing Regulation 2023/1773).
Weeks 3-6: Data and Process Preparation
The core of definitive phase readiness is data. Without accurate, verifiable facility-level data, your EU importers will be forced to use default values — paying significantly higher CBAM costs and potentially seeking alternative suppliers who can provide better data.
Complete Facility-Level Data Files
The data package to be prepared for each facility:
| Data | Description | Format |
|---|---|---|
| Scope 1 emissions | Direct production emissions | tCO2e |
| Indirect emissions | From electricity consumption | tCO2e |
| Production volume | Total output | tonnes of product |
| Specific emissions | Emissions/production ratio | tCO2/tonne product |
| Energy data | Fuel types and quantities | TJ or MWh |
Importer Communication Protocol
Standardize the data sharing protocol with your EU importers. Prepare data packages compliant with the format and content recommended in the European Commission's CBAM guidance document (European Commission CBAM Guidance, 2024).
Weeks 7-10: Verification and Cost Planning
Launch the Verification Process
Contract with an accredited verifier and begin the first verification cycle. The verification process typically takes 4-8 weeks and includes:
- Verifier review of the monitoring plan
- Site visit and data checks
- Preparation of the verification report
- Issuance of the verification statement
Financial Impact Analysis
Calculate your CBAM certificate cost:
Annual CBAM Cost = Export Volume to EU × Specific Emissions × Certificate Price
The certificate price is linked to the weekly average of EU ETS allowance prices. At the end of 2025, EU ETS prices are in the EUR 60-80/tCO2 range (ICE, 2025).
Weeks 11-13: Final Checks
Checklist
- Facility-level emissions data ready for all CBAM-covered products
- Indirect emissions correctly calculated and included
- Contract signed with verifier
- First verification cycle planned or completed
- Data packages delivered to EU importers
- CBAM cost impact reflected in financial budget
- Carbon price developments (TR-ETS) being monitored
Situations Requiring Urgent Action
If you cannot provide actual facility data with 90 days to go, follow ICAP's recommended approach to at least calculate from facility-level fuel consumption and production data, minimizing reliance on default values (ICAP, 2023). Even basic fuel consumption data converted to emissions using IPCC Tier 1 emission factors is vastly better than relying on default values — which are intentionally set above sector averages and result in higher CBAM costs.
For companies with multiple production facilities, prioritize the facility with the highest export volume to the EU. Getting one facility's data verified and accepted is more valuable than having incomplete data across all facilities.
What Happens If You're Not Ready?
The consequences of entering the definitive phase without preparation are concrete and financial:
Higher costs through default values. Without verified facility data, EU importers must use the Commission's default emission values. These values are calculated at or above the upper quartile of sectoral emission distributions (JRC, 2023). For a typical Turkish EAF steel producer, the difference between actual data (~0.5 tCO2/tonne) and default values (~1.3 tCO2/tonne) translates to roughly EUR 60 more per tonne in CBAM costs at current EU ETS prices. Over 100,000 tonnes of annual exports, that's EUR 6 million in avoidable costs.
Customer relationship risk. EU importers facing higher CBAM costs due to their suppliers' inability to provide verified data will seek alternative suppliers who can. The competitive landscape is shifting: data-ready suppliers are becoming preferred partners.
Verification bottleneck. Accredited verifier capacity is limited, particularly for CBAM-specific verification in Turkey. Companies that wait until the definitive phase to seek verifiers may face waiting lists and rush premiums. Early movers have already secured verifier relationships.
Definitive Phase Expectations
| Topic | Transitional Period | Definitive Phase |
|---|---|---|
| Financial obligation | None | CBAM certificate purchase |
| Verification | Optional | Mandatory (accredited verifier) |
| Default values | Limited use | Very limited/none |
| Carbon price deduction | Reporting only | Actual deduction applied |
| Penalties | Limited | Financial penalties in force |
Action Item: 90 days is short but sufficient — your priorities should be closing data gaps and contracting a verifier. These two steps represent 80 percent of definitive phase readiness. The cost of inaction is not abstract: it is measurable in Euros per tonne, per shipment, per quarter.