EU trade is entering the most significant period of regulatory change in years. Two new systems – CBAM (the Carbon Border Adjustment Mechanism) and EUDR (the EU Deforestation Regulation) – introduce entirely new obligations for importers, exporters, and the entire logistics sector. Their common denominator is clear: environmental transparency is becoming a prerequisite for access to the EU market.
Although some provisions are still being clarified, the direction of change is unambiguous. The new regulations mean additional documentation and reporting requirements, as well as the need for close cooperation between trading companies, non-EU suppliers, logistics operators, and customs authorities. 2026 is no longer a distant prospect – for many companies, it is the last moment to prepare their processes.
CBAM – CO₂ emissions reach the EU borders
The second pillar of change is CBAM (Carbon Border Adjustment Mechanism), a mechanism designed to equalize the cost of CO₂ emissions between EU producers and companies outside the Union. Its purpose is to prevent “carbon leakage,” i.e. the relocation of production to countries with lower environmental standards.
CBAM covers goods with high “embedded” emissions resulting from the production process. Currently, these include:
- iron and steel,
- aluminium,
- cement,
- fertilizers,
- hydrogen,
- electricity.
Although the list is relatively short, these are fundamental goods for construction, infrastructure, machinery, automotive industries, and agriculture. The EU does not rule out extending the scope of CBAM in the coming years.
Two stages of CBAM implementation
Stage 1 – Transitional period (2023–2025)
Importers were required to submit quarterly reports on emissions related to the production of imported goods. There was no obligation to purchase certificates yet, but reporting helped establish processes for obtaining data from non-EU suppliers.
Stage 2 – Full implementation from 1 January 2026
From this date, CBAM will apply in full. This means:
- the need to obtain Authorized CBAM Declarant status,
- the obligation to purchase and surrender CBAM certificates corresponding to CO₂ emissions,
- obtaining verified data from manufacturers,
- maintaining detailed documentation in line with European Commission guidelines.
In addition, importers must remember the annual threshold of 50 tonnes – exceeding it without the required status may result in customs clearance being suspended. Already in January 2026, it will also be necessary to submit the CBAM report for the last quarter of 2025.
EUDR – the end of anonymous supply chains
EUDR (EU Deforestation Regulation) is one of the most ambitious environmental regulations introduced by the European Union. Its aim is to limit the import and export of products linked to deforestation and forest degradation. The EU wants to ensure that goods placed on its market come from legal, responsible, and fully traceable sources.
The regulation requires companies to demonstrate that a product:
- does not originate from land deforested after 31 December 2020,
- was produced in accordance with the laws of the country of origin,
- has full supply chain traceability – down to a specific plantation, farm, or plot of land.
In practice, this means collecting detailed geolocation data, information about producers, and submitting Due Diligence Statements (DDS) before placing goods on the EU market or exporting them.
Which products are covered by EUDR?
The regulation applies to seven groups of raw materials considered key drivers of global deforestation:
- wood,
- coffee,
- cocoa,
- soy,
- palm oil,
- natural rubber,
- cattle (and derived products, including leather).
Importantly, EUDR covers not only raw materials but also hundreds of processed products, even if they contain only a minimal share of these materials. In practice, the regulation may apply to furniture, paper, chocolate, cosmetics, animal feed, tyres, leather clothing, or food additives.
The scope of EUDR is determined solely on the basis of customs classification (CN/TARIC), not commercial product names. Therefore, every importer and exporter should carefully analyze their goods in terms of customs codes and the availability of data required by the regulation.
EUDR application deadlines
- 30 December 2026 – medium and large companies,
- 30 June 2027 – micro and small enterprises.
The absence of a DDS number or the correct TARIC code during customs clearance creates a real risk of shipment detention, delivery delays, or even the return of goods to the sender.
Logistics and customs clearance in the new reality
From an operational perspective, it is crucial to note that logistics operators cannot act on behalf of clients in obtaining DDS numbers or Authorized CBAM Declarant status. All required numbers and statuses must be in place before shipment dispatch.
Shipments with incomplete documentation will be held by customs authorities until the data is completed, resulting in delays, additional costs, and a risk of supply chain disruptions.
Green regulations – real consequences
CBAM and EUDR are not only elements of the EU’s climate policy but also new, strict conditions for conducting import activities. Although the application dates may still change as a result of decisions by EU institutions, the direction is clear: environmental transparency is becoming a condition for access to the EU market.
For importers, freight forwarders, and logistics companies, this means the need to rapidly adapt procedures, reporting systems, and cooperation with suppliers. 2026 is approaching faster than it seems – and at the EU’s green border, there will be no room left for improvisation.
