CBAM is in its definitive phase, and what that asks of a Brazilian supplier

Since 1 January 2026 the EU Carbon Border Adjustment Mechanism is no longer a reporting exercise: imports of cement, iron and steel, fertilisers and aluminium now carry a certificate cost. What the dates are, who is exempt, and what a Brazilian supplier is actually asked to provide.

Last reviewed 17 August 2026

What changed on 1 January 2026

CBAM ran from October 2023 as a transitional, reporting-only regime: importers filed quarterly reports on the emissions embedded in certain goods, and paid nothing. That phase is over. Since 1 January 2026 the mechanism is in its definitive regime, and imports made during 2026 create a real financial exposure settled with CBAM certificates.

Two consequences follow for anyone buying from Brazil. Emissions figures now have to be verified rather than estimated, and the number your supplier gives you is no longer a data-collection formality — it determines a cost. That changes how carefully both sides need to treat it.

The dates that matter

The definitive regime began on 1 January 2026. Importers who needed authorised CBAM declarant status but did not yet hold it had to have applied by 31 March 2026 in order to keep importing while the application was pending.

CBAM certificates become purchasable through the central platform in the CBAM registry from February 2027, covering emissions embedded in 2026 imports. The first annual CBAM declaration, for calendar year 2026, is due by 30 September 2027, and annually on 30 September thereafter. From 2027 declarants must also hold certificates covering at least 50% of embedded emissions at each quarter end.

The 50-tonne threshold removes most importers, not most emissions

A de minimis threshold exempts importers whose cumulative annual imports of cement, iron and steel, fertilisers and aluminium goods stay at or below 50 tonnes of net mass. It is deliberately calibrated: it takes roughly nine in ten importers out of the obligation while still capturing the large majority of embedded emissions.

Electricity and hydrogen have no mass threshold at all. If you import either, the obligation applies from the first unit.

The threshold is cumulative across the covered goods and across the year, not per shipment and not per product. An importer who has never thought about CBAM because no single consignment looked significant can still cross it.

Which Brazilian trade this reaches

CBAM covers cement, iron and steel, fertilisers, aluminium, electricity and hydrogen, together with selected precursors within those sectors. Brazilian iron, steel and aluminium lines are the ones most likely to bring an EU buyer into scope.

Note what is absent. CBAM does not cover soy, beef, coffee, cocoa, timber or leather. The Brazilian supply chains that dominate the deforestation conversation are almost entirely outside it, and the Brazilian suppliers it does reach are industrial rather than agricultural. If your Brazilian exposure is agricultural, CBAM is very likely not your problem and the EUDR is.

What a supplier is actually asked for

The obligation sits on the EU importer, not on the Brazilian producer. But the importer cannot discharge it alone: the embedded emissions of the goods are a fact about the production installation, so in practice the request travels up the chain to the supplier, and now with verification attached.

For a Brazilian exporter the practical readiness question is whether installation-level emissions data exists in a form someone else can verify, and whether the same figures can be produced again next year on the same basis. A number assembled once for a single buyer is worth much less than a repeatable one.

What we can and cannot tell you

We hold no emissions data, no installation-level carbon figures, and no CBAM filings. None of that is published per-company in any source we can reach, and we will not imply otherwise. Nothing on this site will tell you a Brazilian supplier’s embedded emissions.

What the registers here cover is the environmental, labour and sanctions record — IBAMA embargoes, the Lista Suja, CEIS/CNEP, international sanctions. That is the part of a supplier file a buyer assembles alongside a CBAM figure, not instead of it. Treating this site as a CBAM tool would be a mistake in either direction.

This could still change

This page describes the position as at 17 August 2026, drawing on the European Commission and national competent authority guidance current on that date. CBAM has been amended more than once, including the simplification package that introduced the 50-tonne threshold, and the scope is expected to widen to further sectors. Anyone making a commercial or filing decision should confirm the current position with the Commission, their national competent authority or their own counsel rather than with us.

Common questions

Is CBAM the same thing as the EUDR?

No, and they barely overlap. CBAM is about carbon embedded in industrial goods — cement, iron and steel, fertilisers, aluminium, electricity, hydrogen — and creates a certificate cost. The EUDR is about deforestation in agricultural and forestry commodities such as soy, cattle, coffee, cocoa, timber, palm oil and rubber, and creates a due-diligence filing. A Brazilian steel supplier is very likely in scope of one and not the other.

We import well under 50 tonnes a year. Are we finished with CBAM?

Probably, but check the arithmetic rather than assuming. The threshold is the cumulative net mass of all covered goods across the whole year, not per consignment or per product line, and electricity and hydrogen are outside the threshold entirely.

When do we actually pay anything?

Certificates become purchasable from February 2027 for emissions embedded in 2026 imports, and the first annual declaration covering 2026 is due by 30 September 2027. The exposure is created by 2026 imports even though settlement comes later, which is why the figures being collected now matter.

Does BrazilTrace report a supplier’s carbon emissions?

No. We hold no emissions or installation-level carbon data, and it is not published per-company anywhere we can reach. We would rather say that plainly than let a compliance page imply a coverage we do not have.

Every figure we publish carries its source and the date we retrieved it — see the methodology, or check a company against the forced-labour register directly. This guide is general information, not legal advice.