The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. It now attaches a carbon-price adjustment to imports of specified goods identified by customs codes in the cement, iron and steel, aluminium, fertiliser, electricity and hydrogen sectors. Subject to the detailed rules, EU importers or their indirect customs representatives must hold authorised CBAM declarant status once the applicable threshold is crossed; the annual 50-tonne exemption does not apply to electricity or hydrogen.
For goods imported during 2026, the first annual CBAM declaration and surrender of certificates are due by 30 September 2027. EU importers may use Commission default emissions values or actual emissions values, but actual values must be verified by an accredited CBAM verifier. The number of certificates can also reflect the phased EU ETS free-allocation adjustment and, where properly evidenced, a carbon price effectively paid in the country of origin.
The formal declaration and certificate duties generally fall on the EU declarant, not the Indonesian producer. Nevertheless, Indonesian exporters may face significant commercial and data requests from EU customers. Producers of potentially covered goods should confirm the relevant customs codes and importer volumes, establish a defensible 2026 emissions-monitoring trail and address data access, verification costs, carbon-price evidence and CBAM-related price allocation in supply contracts.
This publication does not constitute legal advice and should not be relied on as a substitute for advice on specific circumstances.