The entry into force of the definitive phase of the Carbon Border Adjustment Mechanism, from 1 January 2026, has turned a regulatory matter into a concrete cost and supply chain variable that can no longer be ignored.

A regulation that has changed in nature

For years, CBAM —the European carbon border adjustment mechanism — was perceived as a future bureaucratic compliance requirement: something to monitor, but not yet to manage operationally. That period is now over.

From 1 January 2026, the European Union has launched the definitive phase of CBAM. This is no longer simply a matter of reporting the emissions embedded in imported products: real costs have now come into effect. Products subject to the mechanism — including steel fastening systems classified under customs heading 7318 — imported into the EU must be accompanied by the purchase of CBAM certificates proportional to the embedded CO₂ emissions.

The change is not merely accounting. It is structural. And for anyone managing global supply chains in the fastener sector, it is rewriting the rules of the game.

The default values problem: an underestimated risk

At the heart of CBAM’s operational complexity lies a fundamental distinction: that between actual, verified emission data from suppliers and the default values published by the European Commission by country of origin and CN code.

In theory, the virtuous path is clear: the supplier measures its emissions, has them verified by an accredited body, and the importer uses that data to calculate the actual CBAM costs. In practice, this path is currently feasible only to a limited extent.

The reasons are multiple and structural. The accreditation of verifiers by European national accreditation bodies was not yet complete at the start of 2026, meaning that the number of auditors available for mandatory on-site physical verifications — required in the first year — remains insufficient relative to demand. Verifications involve thousands of producers distributed worldwide. And the deadline for submitting the annual CBAM declaration for 2026 imports is set at 30 September 2027: a seemingly wide window, but extremely tight given that 2026 data can only be verified from 2027 onwards.

The practical result is that most European importers of fastening systems will find themselves — at least for 2026 — having to use default values. And this is where the numbers become disruptive.

What do default values actually cost?

The Commission has published specific default values by country of origin and product code. For hexagon head screws (7318 15 88), taking a certificate price of €80 per tonne of CO₂ as a reference, CBAM costs per tonne of imported product vary significantly depending on provenance:

• Vietnam: approx. €136/tonne
• India: approx. €277/tonne (+100% vs Vietnam)
• China: approx. €313/tonne (+130% vs Vietnam)
• Turkey: approx. €394–449/tonne (+190–230% vs Vietnam)

By comparison, an importer using verified actual data — estimating approximately 2 tonnes of emissions per tonne of fasteners — would pay between €50 and €100/tonne.

The gap between actual data and default values can therefore be a factor of 3 to 5. On significant volumes, this delta translates into budget impacts potentially in the range of 30–50% of product cost.

To this is added an escalation mechanism: default values will be increased by 10% in 2026, 20% in 2027, and 30% from 2028 onwards, to discourage reliance on the backstop and push towards verification of actual data. The CBAM factor — the share of emissions not covered by free certificates under the EU ETS — will progressively decrease until 2034, further increasing costs for importers.

Three operational priorities

Against this backdrop, the impact on procurement is direct. Anyone managing global fastener supplies must address at least three immediate operational challenges.

1. Authorised declarant status

From 1 January 2026, importing CBAM goods into the EU without being an authorised declarant is non-compliant. This is not a formality: in the first weeks of the year, there were already cases of goods held at the border because customs declarations did not include an authorisation code or in-progress application reference number.

The authorisation procedure is managed by individual member states and allows up to 120 days for approval. Those who have not yet initiated the process must do so immediately.

2. Dialogue with non-EU suppliers

The quality of data received from the supplier determines the CBAM cost the importer pays. This makes supply chain communication a strategic function, no longer merely operational.

The message to convey to suppliers is precise: they need to begin monitoring emissions according to CBAM methodology, set up a compliant monitoring system, and be prepared to be verified by an accredited auditor. Suppliers who fail to do so will expose their European customers to the forced use of default values — with the economic consequences described above.

Communication must be standardised: what is required, in what format, by when. This is not a task that suppliers — particularly SMEs — can handle autonomously.

3. Country-differentiated cost modelling

The differential between default values by country makes the sourcing model an active cost factor. A procurement manager comparing offers from China, India, Turkey and Europe without factoring in the implicit CBAM cost is comparing non-comparable prices.

Building a cost model that integrates CBAM — even with current approximations — is essential for sound make-or-buy assessments, renegotiating supply contracts, and setting certificate purchasing strategy for 2027 (when certificates for both 2026 imports and current-year 2027 imports will need to be purchased simultaneously).

The European production factor: a structural advantage made visible by CBAM

CBAM does not create an advantage for European production: it makes it measurable and priced. What was previously an image differential — “made in Italy”, “short supply chain”, “European standards” — is now a quantifiable economic differential.

European fastener producers are not subject to CBAM on their domestic market sales. Their emissions are already incorporated into the EU ETS, with all the obligations and incentives that entails. There is no double taxation, no default values apply, and no uncertainty around verification.

This translates into a series of concrete advantages:

• Cost certainty: no exposure to default values, no variable linked to supplier verification timescales
• Reduced compliance risk: no obligation to manage CBAM declarations for those products
• Administrative simplicity: elimination of a significant portion of CBAM bureaucracy
• Total Cost of Ownership predictability: the real cost does not depend on the evolution of the carbon price applied to imports

In a context where CBAM will continue to increase its incidence over time — both through escalating default values and the progressive reduction of the CBAM factor — European production becomes a risk mitigation variable, as well as a quality one.

The industry facing an imperfect transition

It must be said honestly: the launch of the definitive CBAM phase was far from smooth. The European Commission published nine implementing regulations just two weeks before the 1 January 2026 entry into force. The default values — criticised by many as disproportionately high and not documented in their calculation methodology — are in practice turning CBAM into a punitive tariff on imports, rather than an incentive tool for low-carbon intensity production.

These shortcomings are real and deserve attention. But they do not alter the direction of travel: CBAM is in force, costs are real, and regulatory complexity does not exempt companies from having to manage them.

What to watch in the coming months

Key developments to monitor during 2026 and 2027:

• EU ETS benchmark update (spring 2026): will provide definitive values for CBAM calculations using actual data, reducing current uncertainty
• Completion of verifier accreditation in EU countries: will determine the actual capacity to use real data for 2026 imports
• Possible revision of default values: if the Commission responds to pressure from EFDA and other stakeholders
• UK CBAM launch (January 2027): will come into force without a transitional period, with costs accumulating from day one

The compass for fastener buyers today

CBAM is not yet a perfectly predictable cost, but it is already a real one. Procurement managers who ignore it are building spending plans on incorrect assumptions.

In this context, choosing to rely on European producers — with short supply chains, emissions already reported according to EU standards, and no uncertainty linked to data verification — is not an emotional or symbolic choice. It is a choice that reduces risk, simplifies compliance, and makes total cost more predictable and defensible.

This is the contribution Specialinsert brings to its customers: inserts and fastening systems manufactured in Italy, with the traceability and regulatory certainty that the European market increasingly demands.