The champagne corks in Brussels may have popped too soon. On January 14, 2026, the European Commission released a soaring press statement celebrating the official entry of the Carbon Border Adjustment Mechanism (CBAM) into its "Definitive Regime." In the official narrative, this was a triumph of digitalization: over 10,000 customs declarations verified in real-time, with the system running as smooth as silk. However, if we shift the lens from the desks of Brussels to the customs brokers in Hamburg, the steel traders in Rotterdam, and the customs officials currently drowning in paperwork across the continent, a starkly different picture emerges. What we are witnessing is a carefully whitewashed administrative "cardiac arrest." Forensic-level investigation into the first seven weeks of 2026 reveals that the landing of CBAM is far from the glitz claimed by officials. On the contrary, plagued by suspected low-level data errors, catastrophic approval backlogs, and teetering temporary patches, the mechanism is currently mired in a dual crisis of legality and operations. I. The Absurd "Default Values": When Taiwan’s Stainless Steel "Became" Indonesian Coal If one were to find a single representative footnote for this chaos, the "Default Value Controversy" would be the undisputed choice. For importers unable to obtain precise carbon emission data from upstream factories, the EU’s official "default values" are a lifeline. This was supposed to be a baseline derived from rigorous scientific calculation. Yet, in the 2,400-page document released on December 31, 2025, mere hours before the new rules took effect, industry experts witnessed a jaw-dropping scene. This is not merely a margin of error; it looks more like a metallurgical farce. Industry bodies have pointed out that when the Directorate-General for Taxation and Customs Union (DG TAXUD) established the carbon emission default values for stainless steel from the Taiwan region, the data tables contained suspected structural errors, bearing traces of a "copy-paste" job from Indonesian data structures. The consequence? In the physical world, processing a steel slab into a precision tube requires significant electricity, meaning the finished product should logically have higher emissions than the semi-finished one. Yet, in the table published by the EU, industry players have flagged phenomena where "Taiwanese semi-finished stainless steel allegedly emits more than the finished product," vehemently questioning its rationality. In metallurgy, this is impossible; in a bureaucratic Excel sheet, it became legal reference. More fatally, Taiwan’s stainless steel industry relies primarily on Electric Arc Furnaces (EAF) and scrap recycling, resulting in a relatively low carbon footprint. In contrast, the Indonesian stainless steel industry is highly dependent on Nickel Pig Iron (NPI) and coal-fired power, yielding extremely high emissions. This suspected "slip of the hand" by the EU is akin to forcefully assigning the calorie count of a rich braised pork belly to a light garden salad. This has directly resulted in European buyers of Taiwanese stainless steel facing artificially inflated financial costs. II. A 27% Pass Rate: The 15,000-Strong Army Blocked at the Gate If data controversies are "soft tissue damage," the backlog in administrative approval is a fatal "compound fracture." The core rule of the CBAM definitive stage is simple: without "authorized declarant" status, you cannot import. This means every company wishing to ship a screw or an aluminum sheet into Europe must first secure an "entry ticket." The reality is brutal. According to the Commission’s official press release, by January 7, over 12,000 operators across the EU had submitted applications, with just over 4,100 approved (a pass rate of roughly 34%). However, industry estimates suggest that by late February, applications swelled to approximately 15,000, causing the pass rate to slide to around 27%. Where did the massive remainder go? They are stuck in the overwhelmed approval systems of National Competent Authorities (NCAs). In Germany, due to the deluge of applications, logistics giant DSV issued a public notice stating it could not support clients with CBAM authorization and registration, bluntly forcing thousands of SMEs to crash into the complex reporting system like headless flies. In France, the labyrinthine digital authentication process has turned the application into a maze only a hacker could navigate. To prevent European ports from paralysis, the EU was forced to administer a "painkiller": Customs Code Y238. This is a temporary "hall pass" allowing companies that applied before March 31 but have not yet been approved to keep goods moving for now. But make no mistake, this merely lengthens the fuse on the bomb. III. The Strategy of Silence and the Risk of "Retroactive Reckoning" Faced with industry skepticism, Brussels seems to have chosen the oldest PR strategy: silence. Although industry giants like the Gerber Group issued detailed technical warnings as early as January 9, pointing out the absurdity of the Taiwan/Indonesia data, the industry notes that as of late February, no official "Corrigendum" has been issued to legally revise the default values. The updated Excel version released on February 13 merely added a disclaimer: "information only." This rigid attitude transfers all risk to the enterprises. For companies currently relying on the Y238 temporary arrangement, the real danger is not "whether goods are released," but "whether they will be retroactively penalized." Competent authorities have publicly warned that if an authorization application is ultimately rejected, member states can, under Article 26 (2)/(2a) of the CBAM Regulation, retroactively penalize goods imported during the waiting period. Such fines can, in certain cases, reach 3 to 5 times the standard penalty. In other words, this is not a procedural flaw; it is a compliance risk that could land directly on cash flows and balance sheets. Conclusion: Who Pays the Price for Hubris? CBAM was supposed to be the crown jewel of the EU’s climate ambition, a lighthouse for global green trade. But the opening scene of 2026 makes it look more like an unfinished Tower of Babel. From the "data ghosts" haunting the industry to the severely backlogged approval channels, this "hard landing" exposes a chasm between regulatory ambition and administrative capability. For European importers, every day now is an exercise in navigating through fog. They are forced to calculate not just carbon emissions, but the cost of policy uncertainty. And for the European Commission, if it cannot step out of this arrogant "silence" and clarify these glaring operational controversies, what CBAM loses will be more than just data accuracy; it will be the trust of its global trading partners.

Futures: Overnight, LME lead opened at $1,965/mt, fluctuating downward during the Asian session; it dipped to $1,948.5/mt upon entering the European session, but then rose due to a weakening US dollar index, touching a high of $1,976.5/mt before finally settling at $1,974.5/mt. Overnight, the most-traded SHFE lead 2603 contract opened at 16,665 yuan/mt, briefly touched a low of 16,560 yuan/mt early in the session, then rebounded as bears reduced positions, reaching a high of 16,680 yuan/mt before finally settling at 16,665 yuan/mt, up 0.48%, forming a doji star. On the macro front: As markets awaited a series of US economic data, a weaker US dollar made dollar-denominated commodities more attractive to overseas buyers; spot gold extended gains. The White House's Hassett predicted worsening employment: AI boosts productivity, reduces labor demand. Alphabet planned to raise about $15 billion by issuing US dollar bonds. China's Ministry of Commerce held a symposium with automakers: Multiple measures to promote the expansion and quality improvement of auto consumption. The Shanghai, Shenzhen, and Beijing Stock Exchanges announced a package of measures to optimize refinancing. Seven departments including the Ministry of Human Resources and Social Security provided administrative guidance on employment to leading platform companies and courier firms. Three departments including the Ministry of Finance issued an announcement on tax incentives for re-exported cross-border e-commerce goods. : SHFE lead stopped falling and stabilized, but as the Chinese New Year holiday approached, logistics vehicles halted in some regions, leading to reduced shipments and quotations from suppliers. Only some cargoes self-picked up from primary lead smelters were quoted at premiums of 0-50 yuan/mt against the SMM #1 lead average price ex-works. In the secondary lead sector, more smelters were on holiday and reluctant to sell at low prices, with most enterprises suspending quotations; a few secondary refined lead offers were at discounts of 25 yuan/mt to premiums of 50 yuan/mt against the SMM #1 lead average price ex-works. Downstream enterprises generally entered the year-end wrap-up phase, with minimal inquiries, resulting in thin trading in the spot market. Inventory: On February 9, LME lead inventory decreased by 100 mt to 232,750 mt. As of February 9, SMM lead ingot social inventory across five regions rose to a five-month high. Today's lead price forecast: With previously in-transit lead ingots by rail concentratedly arriving at warehouses, social inventory of lead ingots increased significantly, mainly reflected in Jiangsu and Zhejiang region warehouses. Last week, lead prices fell, prompting lead-acid battery enterprises to conduct relatively concentrated stockpiling of lead ingots, leading to a noticeable decline in lead smelters' in-factory inventory. This week being the last before the Chinese New Year, the final batch of lead-acid battery enterprises will enter the holiday state, further weakening lead consumption. Meanwhile, with the start of the Spring Festival travel season, migrant workers have returned to their hometowns, and the number of vehicles in operation has gradually decreased. Currently, some regions no longer support road transportation. It is expected that the growth momentum of social inventory for lead ingots will slow down, and the inventory buildup of lead ingots is anticipated to be more reflected in the smelters' plant inventories. Overall, lead prices are in the doldrums ahead of the holiday. Data Source Statement: Except for publicly available information, other data are processed by SMM based on public information, market communication, and SMM's internal database model, for reference only and do not constitute decision-making advice.

I. Nickel Price Review During Chinese New Year During the 2026 Chinese New Year holiday (February 15–23), domestic SHFE nickel was closed, while overseas LME nickel prices showed a rebound. Pre-holiday surge: Before the holiday, Indonesia’s Ministry of Energy and Mineral Resources announced that it would lock the 2026 nickel ore RKAB mining quota at approximately 260 million mt. Boosted by this positive news, market sentiment turned bullish. On February 11, LME nickel once surged to $18,070/mt, with the LME nickel 3M contract closing at $17,880/mt that day, a single-day increase of 2.93%. Post-holiday pullback then rebound: After the Chinese New Year holiday began (after February 16), domestic SHFE nickel was closed, and the pre-holiday positive news was digested. During this period, the US dollar index strengthened slightly, putting pressure on LME nickel prices, which pulled back. On February 17, LME nickel closed at $16,830/mt, down 1.81% from the previous trading day. From February 18 to 20, influenced by a tailings landslide incident at Indonesia’s IMIP park, LME nickel prices rebounded noticeably but overall remained volatile below $18,000/mt. II. Key Macro Events and Industry Developments On February 18, a tailings dam landslide occurred at the Indonesia Morowali Industrial Park (IMIP), resulting in casualties. The affected area has currently suspended operations. On February 20, the US Supreme Court ruled that the previous tariff policy of the Trump administration was illegal. In response, the Trump administration quickly invoked "Section 122" to announce a new 10% global tariff, which was further raised to 15% the following day. In terms of geopolitics, US-Iran negotiations have been volatile. Although progress was made in the February 17 talks, core disagreements remain, and the US continues to escalate military threats, increasing geopolitical uncertainty. III. Post-Holiday Outlook Supply side, due to fewer calendar days in February and the Chinese New Year holiday leading to partial shutdowns at some enterprises, production plans have been reduced. Refined nickel production in February is expected to decrease by about 5% MoM. Demand side, post-holiday, as traders and end-users resume production, market transactions are expected to gradually recover. Spot premiums for Jinchuan refined nickel are projected to remain high at 8,000–10,000 yuan/mt, while spot premiums/discounts for domestically produced electrodeposited nickel are expected to stay within the pre-holiday range of -400–400 yuan/mt, with relatively stable fluctuations. After the Chinese New Year holiday, nickel prices are expected to enter a phase of wide swings at elevated levels. On the downside, the 130,000 yuan/mt level for SHFE nickel shows strong resilience due to Indonesia's quota tightening policy; on the upside, the zone above 145,000 yuan/mt faces strong resistance from high inventory and weak demand. The core trading range for the most-traded SHFE nickel contract after the holiday is projected at 130,000-145,000 yuan/mt. Key factors to monitor include whether supply contraction expectations materialize as anticipated, as well as the pace of downstream work resumption and the strength of restocking demand.

On the eve of the Spring Festival holiday, the lithium hydroxide market showed signs of a moderate price rebound. According to SMM data, on February 13, lithium hydroxide was quoted in a range of 130,000 to 145,000 RMB/ton, with an average price of 137,500 RMB/ton, an increase of 5,000 RMB/ton from February 6 (the previous Friday). As of February 13, the average price for February was provisionally reported at 139,575 RMB/ton. From the supply side, the overall lithium hydroxide supply remained tight in February. Although upstream smelters' willingness to release inventory slightly increased due to fluctuations in lithium carbonate futures prices, the overall sentiment to hold firm on prices remained strong, with quotes generally maintained at or above 140,000 RMB/ton. Pre-holiday macroeconomic policy expectations boosted sentiment in the lithium market. Coupled with the fact that few trading days remain in February, the pattern for the monthly average price has been largely set. Consequently, on the demand side, some material manufacturers increased their inquiries before the holiday to secure raw materials for post-holiday production. However, due to relatively sufficient earlier stockpiling and individual leading ternary material enterprises entering maintenance phases, the raw material shortage situation eased somewhat in the short term. Downstream companies showed limited acceptance of high raw material prices, with procurement intentions largely centered around the monthly average price. Overall, market transactions were still dominated by a tug-of-war between quoted prices and psychological price expectations, with actual trading volumes remaining quite limited. During the Spring Festival holiday, the market operated stably overall, with trading activity cooling down significantly. Affected by the hazardous chemical properties of lithium hydroxide, transportation came to a virtual standstill, and the market entered a seasonal quiet period. On the macro front, on the eve of the Spring Festival, the Chinese government announced the implementation of a zero-tariff policy for 53 African countries with which it has diplomatic relations, effective May 1st. It also promotes the signing of agreements on economic partnership for common development to expand market access for African products. This move will further deepen China-Africa economic and trade cooperation. In the long term, it is expected to broaden import channels for resources, including critical minerals, providing more solid resource support for China's new energy industry chain (such as battery raw materials). Meanwhile, significant movements also occurred in the international market. The U.S. Supreme Court's ruling that certain tariff policies from the Trump administration were illegal drove a broad uptick in overseas markets. It is expected that this trend will continue to reinforce domestic market confidence after the holiday. However, the minutes from the Federal Reserve's January meeting revealed significant divergence among policymakers regarding the future path of interest rates, which could exacerbate global capital market volatility and introduce uncertainty for the post-holiday market. Looking ahead to the post-holiday market: On the supply side, due to fewer production days and planned maintenance at some lithium salt plants, February's lithium hydroxide output is expected to decrease by more than 10% compared to January. On the demand side, as material manufacturers gradually resume production after the holiday, raw material procurement demand is expected to be gradually released, and market trading activity may pick up. However, the pace of the demand recovery still faces certain variables. On one hand, changes in the order structure of downstream battery cell manufacturers and the progress of new production line integration may affect the actual raw material procurement rhythm of material manufacturers. On the other hand, the price trends of upstream lithium ore and lithium carbonate, as well as the upcoming second-quarter contract negotiations, will also disturb the cost transmission and market expectations for lithium hydroxide, thereby exacerbating market uncertainty. Overall, the current lithium hydroxide market is in a phase of stabilizing before the holiday and gathering momentum afterward. The tug-of-war between supply and demand intensifies, intertwined with the influence of macroeconomic policies and the external environment. In the short term, prices are expected to remain volatile and range-bound. Subsequent trends will require close attention to downstream production start-up rates and upstream cost changes.

The fundamental challenge in the 304 stainless steel industrial chain is Instrument Asymmetry, a scenario where the dominant cost driver, Nickel Pig Iron (NPI), lacks a direct futures contract and forces participants to manage 75% of their risk using standardized proxies like pure nickel. This creates a lethal threat not from price volatility itself, but from the Basis Risk that occurs when physical assets and hedging tools decouple.

[SMM Analysis: The "Key Anchor Point" in Great Power Rivalry: The US "Treasury Plan" and the Resource Reshuffle in Latin America] As the second phase of the Mirador copper mine project in Ecuador, developed by a Chinese enterprise, remains stuck in a "built but awaiting approval" deadlock, ten thousand kilometers away in Washington, the US Export-Import Bank, together with the President, is announcing a historic supply chain security initiative called the "Treasury Plan." In the pause and the start, a global covert battle over critical minerals such as copper, lithium, cobalt, and gallium is moving from behind the scenes to the forefront.