EU CBAM definitive phase: carbon-price evidence calls open
On 28 August 2025, the European Commission opened three Calls for Evidence to gather data on carbon prices paid in third countries, supporting the drafting of implementing acts for the Carbon Border Adjustment Mechanism's definitive phase. These calls will inform how the EU calculates adjustment payments and validates embedded-emissions data from non-EU producers. Shippers and exporters in covered sectors (cement, steel, aluminium, fertilisers, hydrogen, electricity) should prepare detailed carbon-cost documentation.
Photo: RDNE Stock project / PexelsEU launches evidence-gathering for CBAM definitive phase
On 28 August 2025, the European Commission launched three Calls for Evidence to support the preparation of the implementing acts for the definitive phase of the Carbon Border Adjustment Mechanism (CBAM), according to EU TAXUD.
The Calls for Evidence are designed to gather real-world data on carbon prices and embedded-emissions methodologies in third countries. This information will inform the Commission's drafting of definitive implementing acts that will govern how the EU calculates CBAM adjustment payments and validates carbon-cost claims from non-EU producers.
The synopsis report for these calls is publicly available, detailing the scope of evidence sought and the submission timeline.
The definitive CBAM phase represents a structural shift from the current transition period (October 2023–December 2025). During the definitive phase, importers and authorised declarants will be required to hold CBAM certificates corresponding to the embedded emissions in covered goods. The three evidence calls are expected to clarify:
- Carbon prices and costs borne by producers in key exporting countries
- Methodology for calculating or estimating embedded emissions where data is unavailable
- Administrative and compliance procedures for third-country producers and EU importers
Who is affected
Shippers, freight forwarders, and exporters in the following sectors face direct impact:
- Chapter 25: Mineral products (cement clinker, raw materials)
- Chapter 72: Iron and steel
- Chapter 73: Articles of iron and steel
- Chapter 76: Aluminium and articles
- Fertilisers, hydrogen, and electricity (recently added to CBAM scope)
Producers in third countries exporting these goods to the EU must now prepare to demonstrate and document the carbon costs and embedded emissions in their products. Importers and authorised declarants will need to verify and report this data when registering CBAM certificates.
What this means for shippers
Exporters in CBAM-covered sectors must begin auditing and documenting carbon costs in their supply chains immediately. The definitive implementing acts, informed by these evidence calls, will set the baseline for how the EU validates carbon-price claims from mid-2026 onward. Failure to prepare verifiable carbon-cost data will delay customs clearance and increase duties. Freight forwarders should advise clients to engage with the Commission's evidence-call consultation and begin collecting embedded-emissions documentation now. Check your HS codes and carbon-cost methodology against the upcoming implementing-act requirements.
