Next month sees the full implementation of climate legislation that is already reshaping global decarbonization efforts. But many sustainability professionals remain only dimly aware of its existence.
By deciding to charge a fee on the embodied carbon in imports from hard-to-abate sectors, the European Union has triggered new climate initiatives around the world. Companies in affected industries and beyond are scrambling to improve data gathering and looking for emission cuts. And multiple countries have implemented their own carbon-pricing schemes in a bid to lower costs for exporters.
“This is a moment when carbon risk stops being a footnote in a sustainability report and really starts showing up in the profit and loss,” said David Linich, a sustainability partner at PwC.
Those in directly affected industries will likely be familiar with the Carbon Border Adjustment Mechanism (CBAM). Companies that import products into the EU from industries covered by the law — cement, aluminum, electricity, hydrogen, fertilizers and iron and steel — already have to report the embodied carbon in their purchases. From January onwards, importers will also be subject to a fee for that carbon. The price will be pegged to the EU Emissions Trading Scheme, where allowances currently trade for around $90 per ton of carbon dioxide equivalent
Trellis spoke with consultants, trade organizations and sustainability professionals to understand how the impact of CBAM will ripple out beyond the sectors covered by the legislation. Here are three key points to consider.
CBAM’s impact is broad — and could get more so
The legislation only covers six industries at present, but many other sectors are or will be affected.
Take emissions data. Companies that import steel and other covered products into the EU are being asked by buyers to provide detailed greenhouse gas numbers. To gather that information, exporters are turning to their suppliers for data, who in turn are passing requests to their suppliers. “It resonates through the entire supply chain,” said Jennifer McIsaac, chief market intelligence officer at ClearBlue Markets, a consultancy.
That’s going to mean more work for some sustainability teams, but it also presents competitive opportunities. Tracking emissions data through complex supply chains requires cooperation from experts in procurement, sustainability, legal and other departments. “Those companies that break down those silos the fastest will, we believe, manage risk at the lowest cost,” said Linich.
CBAM’s direct impacts may also grow. At present, the regulation applies to raw materials. But that risks handing a competitive advantage to manufacturers outside the E.U., which can use the same materials without paying a carbon fee and then import their products into the region. Media reports suggest that the EU is considering countering that by expanding the legislation to some finished products, including car doors and stoves. The scheme is also designed to be expanded to other industries, with chemicals potentially coming next.
Get ready to compete on carbon
Solventum, a healthcare company spun off from 3M in 2024, is exposed to CBAM through aluminum and steel imported into Europe by its dental, filtration and purification businesses. After talking to suppliers and estimating the quantity of carbon involved, Sustainability Director Maria Watson decided it would be more efficient to use default emission values for the imported products rather than chasing down primary data.
Now that she has those numbers — and the associated costs — she is educating other areas of the business about the impacts. “This gives us a way to encourage our R&D teams to consider alternative materials that would ensure patient safety and quality with lower embodied carbon,” she said.
These competitive forces will be felt across industries and even at the national level. Total costs in the steel sector, for instance, where the import fee on some products could reach 20 percent, are likely to be far higher than other industries, according to a report published this month by Fastmarket, a price-reporting agency. The impacts won’t be evenly distributed, however: Indian companies, for example, are expected to lose out to rivals in the U.S. that have done more to adopt lower-carbon production methods.
That could be good news for South Korea’s steel companies, which also have lower emissions. But the country might experience the opposite impact if CBAM is expanded to include semiconductors. Chip exporters could then face close to $590 million in CBAM costs between 2026 and 2034, according to a study released this month by the Institute For Energy Economics And Financial Analysis.
“The sharp increase in CBAM costs may prompt European importers to switch their chip suppliers from high-emission-intensive producers to low-carbon providers to limit financial exposure,” the authors concluded.
Carbon pricing is going global
Exporters face reduced CBAM fees if they pay a domestic carbon fee, a feature of the legislation that has heightened global interest in emissions trading schemes. Brazil, India and Turkey have accelerated efforts in this area since CBAM went into force in 2023, according to a report issued this summer by the International Emissions Trading Association, a nonprofit that promotes carbon markets. At the start of this year, the report noted, 38 trading schemes were in force around the world, covering close to a fifth of global emissions, one-third of the population and 58 percent of GDP.
Exactly how the EU will allow domestic carbon fees to count against CBAM duties is still being worked out. One live issue is carbon credits. Some trading schemes allow companies to use limited types of credits to meet emission obligations. It’s not clear whether the EU would allow credits from other schemes to offset CBAM fees, or which types of credits would qualify. A likely candidate is durable carbon removals, technologies that lock away carbon for hundreds of thousands of years; the bloc is currently considering allowing such credits to be used in its emissions trading scheme.
Demand would likely rise for any credit type given the EU’s blessing, which would in turn affect prices of other kinds of credits, including those companies use to meet carbon-neutral commitments and other emissions claims. “The high tide is going to lift all the ships,” said McIsaac. “The voluntary market could get a boost from this, too.”
