In 2026 the EU's CBAM crossed from "report-only" into a phase where importers pay real money. This piece lays out the five newly-landed implementing regulations, the timetable and thresholds, and — using hot-rolled coil, cold-rolled coil, coated sheet and other flagship traded steels as its sample — draws a cost map from the official country default values. For the same coil of HRC, Indonesia's carbon cost is about 581 EUR/tonne while the USA's is about 15 EUR/tonne: a near-40× gap.

his week, the Chicago Summit clarified the industry timeline: oxide electrolytes will be prioritized for deployment within 2–3 years, while all‑solid‑state sulfide batteries will be delayed until 2028–2030. The Baihu Lake Laboratory achieved a breakthrough in boride‑based solid‑state batteries with 400 Wh/kg, wide temperature range, and low‑pressure operation, targeting low‑altitude economy and robotics applications.

The EU Commission continues to present CBAM as a fairness mechanism, but critics argue the actual framework creates severe asymmetry between importers and domestic steel producers. Under CBAM's Article 31 formula, only a normative allocation entitlement is mirrored, not actual economic relief — domestic mills with benchmark allocations exceeding actual emissions retain tradable surplus allowances, while importers can at best achieve zero liability with no transferable entitlement. Since 2005, European steel producers have received over 3.4 billion free ETS allowances, of which approximately 884 million were surplus — representing a calculated gross value of nearly €71 billion at current carbon prices. The latest ETS reform proposal (COM(2026) 616) fails to address this imbalance, extending free allocation for CBAM sectors to 2038 while leaving historical surplus allowances fully intact. SMEs and downstream processors hold no legacy allowance reserves and must prefinance CBAM certificates upfront, while large steel corporations draw on decades of accumulated surpluses — entrenching rather than resolving the structural asymmetry.

Following the start of the definitive phase of the EU Carbon Border Adjustment Mechanism (CBAM) in 2026, differences in country-specific default values , default production routes and corresponding benchmarks have begun to translate into significantly different theoretical certificate exposures for unwrought aluminium. SMM analysed EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins and matched the trade data with the 2026 default value, default production route and CBAM benchmark assigned to each origin. The theoretical unit certificate exposure in this analysis is calculated as: 2026 theoretical unit certificate exposure = 2026 default value − benchmark × 97.5% × cross-sectoral correction factor The cross-sectoral correction factor, or CSCF, is provisionally assumed to be 1. The calculation does not deduct any qualifying carbon price effectively paid in the country of origin. The results therefore indicate the relative CBAM exposure of different origins under the default-value scenario. They do not represent the final number of certificates that EU importers will be required to surrender or the final monetary cost. EU-27 unwrought aluminium imports rose 7.0% in 2025 According to SMM calculations, EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins reached approximately 7.63 million tonnes in 2025 , up from 7.13 million tonnes in 2024. This represented an increase of about 502,200 tonnes, or 7.0% year on year . Of the 2025 total, approximately 4.56 million tonnes originated from countries subject to CBAM, accounting for 59.7% of total imports. Imports from CBAM-exempt origins, including Norway, Iceland and Switzerland, amounted to approximately 3.05 million tonnes , representing around 40.0% of the total. A further 25,800 tonnes were recorded without a specified origin and were excluded from the country-level exposure ranking. Applying the 2026 default values and benchmarks to the 2025 trade structure produces an estimated theoretical certificate exposure of approximately 4.09 million tCO₂e for imports from CBAM-covered origins. The trade-weighted average unit exposure was approximately 0.898 tCO₂e per tonne of product . As 2025 remained within the CBAM transitional period, these figures are scenario-based estimates using 2025 trade volumes and the 2026 calculation rules. They do not represent actual certificate obligations for 2025. Primary aluminium route accounted for more than 99% of theoretical exposure The primary aluminium route dominated both CBAM-covered import volumes and theoretical certificate exposure. In 2025, imports assigned to the primary aluminium route totalled approximately 4.46 million tonnes , accounting for 97.8% of imports from CBAM-covered origins. Their theoretical certificate exposure reached approximately 4.06 million tCO₂e , representing 99.3% of the total exposure. The trade-weighted average unit exposure for the primary aluminium route was approximately 0.912 tCO₂e per tonne of product . By comparison, imports assigned to the secondary aluminium route amounted to approximately 99,500 tonnes, or 2.2% of CBAM-covered imports. Their theoretical certificate exposure was approximately 30,600 tCO₂e, with an average unit exposure of around 0.307 tCO₂e per tonne . The gap between the two routes reflects differences in both country default values and the applicable benchmarks. For HS/CN 7601, the benchmark used for the primary aluminium route is 1.423 tCO₂e per tonne , compared with 0.091 tCO₂e per tonne for the secondary aluminium route. This means that, under a default-value declaration scenario, the theoretical CBAM exposure of EU-27 unwrought aluminium imports remains highly concentrated in primary aluminium supply. Mozambique recorded the highest unit exposure, with China also ranking near the top The results show a clear divergence in theoretical unit exposure among origin countries. Mozambique recorded the highest unit exposure among major origins with a country-specific default value, at approximately 2.130 tCO₂e per tonne of product . China followed at approximately 1.913 tCO₂e per tonne , placing it among the origins with the highest default-value-based unit exposure. South Africa recorded an estimated unit exposure of approximately 1.207 tCO₂e per tonne , followed by Russia at 0.989 tCO₂e and Canada at 0.769 tCO₂e. Bahrain, the United Arab Emirates, India, the United Kingdom, Egypt and Kazakhstan share similar default values under the primary aluminium route, resulting in unit exposure of approximately 0.670 tCO₂e per tonne . Australia, Brazil, Malaysia, Oman, Qatar, Saudi Arabia and the United States recorded unit exposure of approximately 0.483 tCO₂e per tonne . Origins assigned to the secondary aluminium route generally recorded approximately 0.307 tCO₂e per tonne . A high unit exposure does not necessarily mean that an origin faces the greatest aggregate impact. Total exposure also depends on the volume of trade with the EU-27. China illustrates this distinction. EU-27 imports of HS/CN 7601 products from China reached approximately 12,400 tonnes in 2025 , up 24.3% year on year. This corresponded to theoretical certificate exposure of about 23,700 tCO₂e . China therefore ranked near the top on a unit basis, but its comparatively limited shipment volume to the EU-27 kept its aggregate exposure well below that of Mozambique, Canada and several major Gulf suppliers. Mozambique’s total theoretical exposure reached 1.34 million tCO₂e After incorporating 2025 import volumes, Mozambique emerged as the origin with the highest aggregate theoretical certificate exposure. EU-27 imports from Mozambique reached approximately 628,000 tonnes in 2025 , up 17.5% year on year. Based on unit exposure of 2.130 tCO₂e per tonne, its total theoretical exposure was approximately 1.34 million tCO₂e . Mozambique alone accounted for 32.7% of the theoretical exposure associated with CBAM-covered origins. However, the above total exposure is a static estimate based on 2025 trade volumes. Power supply constraints may limit Mozambique’s aluminium smelting capacity and output in 2026–2027, potentially reducing its exports to the EU. As a result, its actual near-term aggregate CBAM exposure may not reach the theoretical level estimated using 2025 trade volumes. Canada supplied approximately 682,800 tonnes to the EU-27 in 2025. Although its unit exposure was considerably lower than Mozambique’s, its larger trade volume lifted its aggregate theoretical exposure to approximately 524,800 tCO₂e , equivalent to 12.8% of the total. Bahrain, the United Arab Emirates, Russia and South Africa recorded theoretical total exposures of approximately 350,900 tCO₂e, 329,300 tCO₂e, 322,200 tCO₂e and 263,600 tCO₂e, respectively. Mozambique, Canada, Bahrain, the United Arab Emirates, Russia and South Africa together accounted for approximately 76.4% of total theoretical certificate exposure. Mozambique’s position was driven by the combination of a high unit default-value exposure and substantial trade volume. Canada’s unit exposure was not among the very highest, but its large and rapidly increasing export volume significantly amplified its aggregate impact. Four-quadrant analysis places China in the “high intensity, low trade volume” category A four-quadrant analysis using 2025 EU-27 import volume on the horizontal axis and 2026 theoretical unit certificate exposure on the vertical axis provides a clearer view of the combined influence of carbon intensity and trade scale. The core high-exposure quadrant includes Mozambique, Canada, Bahrain, the United Arab Emirates, Russia, South Africa, India and the United Kingdom. These origins combine comparatively large trade volumes with relatively high unit exposure and are the main contributors to aggregate CBAM exposure for EU-27 unwrought aluminium imports. China is the most prominent origin in the high intensity, low trade volume quadrant . Its theoretical unit exposure of approximately 1.913 tCO₂e per tonne is second only to Mozambique, but its current export volume to the EU-27 remains comparatively limited. Ukraine and South Korea are among the origins in the trade-volume-driven quadrant . Both are assigned to the secondary aluminium route and have relatively low unit exposure, but their larger trade volumes increase their aggregate exposure compared with other secondary-route origins. Vietnam, Morocco, Serbia, Bolivia and Mexico are among the origins in the low-exposure quadrant , reflecting both lower unit exposure and limited trade volumes. For Vietnam, HS/CN 7601 unwrought aluminium is assigned to the secondary aluminium default route, resulting in theoretical unit certificate exposure of approximately 0.307 tCO₂e per tonne in 2026, significantly below that of most origins assigned to the primary aluminium route. EU-27 imports from Vietnam amounted to approximately 7,100 tonnes in 2025, down around 27.1% year on year, corresponding to theoretical total certificate exposure of about 2,200 tCO₂e. Vietnam’s overall CBAM exposure therefore remains relatively limited at present. However, should its exports to the EU expand in the future, access to and verification of actual emissions data will remain an important factor affecting the relative competitiveness of Vietnamese products. The quadrant thresholds are analytical dividing lines based on the median values of CBAM-covered origins with actual trade. They do not represent regulatory thresholds set by the EU. Theoretical exposure reached approximately 642,400 tCO₂e in Q1 2026 In the first quarter of 2026, EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins reached approximately 1.52 million tonnes , with a total import value of around €4.36 billion . The average import value was approximately €2,873 per tonne . Imports from CBAM-covered origins amounted to approximately 782,800 tonnes , accounting for 51.6% of total imports. Imports from CBAM-exempt origins reached around 733,000 tonnes, or 48.4%. Based on the 2026 default values and benchmarks, imports from CBAM-covered origins generated theoretical certificate exposure of approximately 642,400 tCO₂e during the quarter. Mozambique remained the largest contributor, with theoretical exposure of around 150,500 tCO₂e. Canada followed with approximately 86,800 tCO₂e, the United Arab Emirates with 82,100 tCO₂e, Bahrain with 63,400 tCO₂e and South Africa with 56,200 tCO₂e. As the analysis does not include Q1 2025 comparison data, no year-on-year conclusion has been drawn for Q1 2026 import volumes or exposure. The quarterly figures are used primarily to illustrate the origin structure during the initial stage of the definitive CBAM period. Access to and verification of actual emissions data could become an important competitiveness factor Country default values are fallback parameters applied when producers are unable to provide actual emissions data that meet EU requirements. They do not necessarily reflect the actual carbon intensity of a specific producer or shipment. For origins with relatively high default-value exposure, including China, Mozambique, South Africa and Russia, producers whose actual embedded emissions are materially lower than the applicable country default value could reduce the certificate exposure faced by EU importers by establishing robust emissions-monitoring systems and providing complete, verified emissions data. Conversely, where suppliers are unable to provide emissions information that is complete, traceable and compliant with EU requirements, importers may have to rely on the relevant country default value. A higher default value could consequently affect supplier selection, purchase negotiations and long-term contract arrangements. The final number of certificates to be surrendered will also depend on actual embedded emissions, production-route classification, data verification and any qualifying carbon price effectively paid in the country of origin. The actual CBAM cost will additionally depend on the CBAM certificate price, which is linked to EU Emissions Trading System allowance prices. The theoretical certificate exposure calculated in this analysis should therefore not be interpreted directly as either the final certificate obligation or the final CBAM cost. Overall, the impact of CBAM on trade in HS/CN 7601 unwrought aluminium will not be determined by country default values alone. Unit certificate exposure, trade scale, actual emissions and the availability of reliable carbon data will jointly shape the competitive position of different origins and producers in the EU market. As the definitive phase progresses, differences in low-carbon production capability, emissions-data management and verification capacity are likely to become increasingly visible in procurement decisions, export competitiveness and trade flows. Data note: The trade scope covers EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins. CBAM-exempt origins, including Norway, Iceland and Switzerland, are included in total import statistics but excluded from theoretical certificate exposure. Origins without a country-specific default value are assigned the applicable value for “Other Countries and Territories.” Unspecified origins are excluded from the country ranking. Theoretical exposure does not deduct qualifying carbon prices paid in third countries. Source: EU-27 import data, EU CBAM default values and benchmarks; compiled by SMM.

Rising compliance costs, a verification bottleneck, and tightening EU import quotas combine to reshape the competitive landscape for Asian stainless steel suppliers in Europe from 2026 onward. The EU CBAM entered its definitive implementation phase on January 1, 2026 — transitioning from a reporting exercise into a mechanism with real trade cost implications.

The EU Parliament's ENVI committee approved by 70% a draft report extending CBAM to downstream products including cars, appliances, furniture, building materials, and agricultural machinery, with implementation targeted from 2028. With the current EU carbon price at around EUR 80/tonne — projected to reach EUR 140 by 2030 and EUR 250 by 2045 — the expansion is set to systematically raise the cost of imported everyday goods and increase compliance burdens for SMEs, with no compensation mechanism in place. ACEA criticized the plan as technically flawed and inconsistent, calling for a postponement to at least 2030. Separately, EUROFER's claim of losing 30 million tonnes of capacity and 30,000 jobs over five years has drawn scrutiny: its own data shows actual job losses of around 17,000, while the capacity decline reflects reduced crude steel production rather than installed capacity — partly because European producers substituted slab imports from Russia, China, Brazil, and Indonesia to protect downstream margins, while holding accumulated free ETS certificates worth an estimated EUR 56 billion.

In yesterday's [SMM Analysis] EU Steel Tariff Wall Doubles to 50%: Reconstructing the New Quota System & In-Depth Analysis of 1A HRC, SMM deeply analyzed the brutal allocation logic of the EU's new 18.35 million tonnes quota. When the "50% tariff wall" and the "melting and pouring" rules completely block traditional tax-free export paths, the global steel supply chain is undergoing a forced reshuffle. Today, we shift our perspective to the ripple effects and macro-level forecasts of this storm.

[SMM Steel] European carbon prices for December 2026 EUA contracts rose to around €79/t in late May, supported by volatility in energy markets, optimism over a potential EU-UK carbon market linkage, and ongoing discussions on EU ETS reform. Market participants noted that UK carbon prices surged 6% on May 26 to £56.67/t, while EUAs climbed above €79/t on May 27. Meanwhile, six EU countries including Poland, Czech Republic, and Greece called for greater protection for heavy industry through increased free carbon allowances amid high energy costs and geopolitical pressures. The EU is expected to conduct a mid-term ETS review by July 2026.

[SMM Steel] The European Commission released a draft regulation clarifying how importers can deduct carbon costs already paid in third countries from CBAM certificate obligations. The draft outlines detailed rules covering carbon price calculation methods, verification procedures, supporting documents, and supply chain traceability requirements. Under the proposal, companies can offset carbon taxes, carbon fees, or ETS costs paid in the production country only if the costs are directly linked to product emissions, exclude government subsidies or rebates, and are supported by transparent and verifiable emissions data. The regulation is expected to become a key supporting framework for CBAM’s full operational phase.

【SMM Steel】The EC has released draft implementing rules for deducting carbon prices paid in third countries from CBAM certificate obligations. Companies seeking to offset carbon taxes, fees, or trading costs must meet strict conditions: carbon costs must be directly linked to product emissions, exclude subsidies or rebates, and be backed by verifiable and traceable data. The regulation is a key supporting rule for CBAM's operational phase.