CBAM and industry: beyond compliance, towards new supply chain choices

In recent months, the term CBAM has begun to appear more and more frequently in conversations between industries, suppliers, and purchasing departments. It is a mechanism that is set to have a clear and concrete impact on European production chains.

The Carbon Border Adjustment Mechanism (CBAM) is a tool introduced by the European Union with a specific objective: to reduce the risk of industrial production being moved outside Europe to countries with less stringent environmental standards, generating unfair competition and higher global emissions. In practice, the CBAM introduces a system for offsetting CO₂ emissions associated with products imported from non-EU countries, aligning them with the environmental costs already incurred by European companies.

In its initial phase, the CBAM covers key materials such as steel, aluminum, cement, and energy: sectors that form the basis of many industrial supply chains, including that of fasteners and bolts. Even companies that do not directly import these materials but purchase them along the supply chain will gradually begin to face new reporting requirements, greater traceability, and increasing attention to the emissions embodied in products.

How does it work?

With its entry into the final phase, the CBAM has become a fully operational mechanism, with concrete effects not only in terms of information but also economically. Today, companies importing certain categories of carbon-intensive goods into the European Union are required to declare annually the CO₂ emissions embodied in the imported products and to cover those emissions through the purchase of CBAM certificates. The price of the certificates is aligned with that of the European ETS allowances, so as to ensure a level playing field between domestic production and extra-EU imports.
In practice, the CBAM extends to goods entering the European market the same principle already applied to European companies: those who place products with a high emissions impact on the market must bear the related environmental cost. This step makes the issue of emissions traceability along the supply chain central to procurement decisions. It is no longer just a matter of complying with a regulatory obligation, but of rethinking the relationship with suppliers, the quality of available data, and the ability to manage information that is increasingly strategic for business competitiveness.

Who does this apply to? Who is exempt?

The CBAM does not apply indiscriminately to all companies, but specifically to those who import certain categories of carbon-intensive goods into the European Union. Those directly affected are importers—or, in some cases, their indirect customs representatives—who place products such as steel, aluminum, cement, fertilizers, electricity, and hydrogen on the European market. It is important to note that the obligation does not depend on the sector in which the company operates, but on its role in the import chain: even a distributor or B2B retailer may fall fully within the scope of the CBAM if it is the entity that clears the goods through customs.
On the other hand, companies that import quantities below the annual threshold set by the regulation (which is 50 tons) are exempt from CBAM obligations, as are those that purchase only goods produced within the European Union. However, even for formally exempt companies, the CBAM is not irrelevant: the growing focus on the traceability of emissions along the supply chain means that the information requirements for importers are gradually being reflected in suppliers and trading partners as well. In this sense, the CBAM is not just a rule that distinguishes between obligated and exempted parties, but a factor that influences the entire industrial ecosystem, redefining criteria for selection, collaboration, and reliability along the supply chain.

What are the implementation phases? What will change from January 1, 2026?

The CBAM was designed with a two-phase structure, precisely to allow companies and supply chains to adapt gradually to a profound change.

The first phase, launched in October 2023, was transitional and focused exclusively on data collection: importers were required to report the quantities of goods imported and the CO₂ emissions incorporated, without any economic obligation. This period served as a “learning” phase, useful for testing methodologies, information systems, and collaboration flows with suppliers.
From January 1, 2026, with the start of the final phase, the CBAM changed in nature: reporting was accompanied by a direct financial impact. Affected companies must now submit an annual declaration and purchase CBAM certificates in proportion to their declared emissions, at a price aligned with that of ETS allowances. The mechanism thus becomes fully operational and transforms environmental data into a real economic variable, affecting purchasing strategies, costs, and supply chain relationships within the European Union.

To accompany this transition, the European Commission has introduced the Omnibus simplification package, with the aim of reducing administrative complexity, especially for smaller businesses. The main changes include: the introduction of a minimum applicability threshold based on import volumes, the extension of deadlines for certain deadlines, and greater flexibility in data and authorization management. These measures do not change the structure of the CBAM, but make its implementation more gradual and sustainable, without reducing its environmental and competitive effectiveness.

How do climate and ESG regulations integrate?

The CBAM is not an isolated measure, but part of a broader framework of climate and ESG regulations that are redefining how companies measure, report, and manage their environmental impact. On the one hand, the CBAM introduces an operational mechanism that assigns a cost to the CO₂ emissions embodied in imported products; on the other hand, ESG regulations are pushing companies to report their environmental, social, and governance impacts in a structured way, increasingly including emissions along the supply chain. In this context, the data required by the CBAM—in particular those relating to emissions associated with purchased materials—become a consistent information base for ESG reporting as well, especially with regard to indirect emissions and supply chain transparency.

For companies, this means that CBAM and ESG obligations should not be managed as separate processes, but as parts of a single process: the ability to collect reliable data from suppliers, interpret it correctly, and integrate it into internal systems becomes central to both regulatory compliance and credibility with customers, partners, and the market. In other words, CBAM helps to make measurable and verifiable what, until recently, often remained a statement of principle in ESG strategies, strengthening the alignment between climate objectives, operational choices, and corporate responsibility within the European Union.

A practical view of this new reality

More than just a regulation, CBAM marks a change in approach: it is not only about compliance with rules, but also about how companies choose suppliers, build supply chain relationships, and plan their industrial future. That is why we decided to complement our technical analysis with a more concrete and entrepreneurial perspective, gathering the views of those who experience the market, its complexities, and its developments on a daily basis. We therefore interviewed Paolo Scopel, founder of Univiti, to understand how the CBAM is changing the dynamics of the sector and what strategic insights it can offer to those operating in industrial B2B.

When you first heard about CBAM, what was your initial reaction as an entrepreneur?

My initial reaction was one of caution. Not so much because of the cost itself, but because of the uncertainty: new rules, incomplete data, different interpretations. As an entrepreneur, when a regulation is still being finalized, the most important thing is to understand it thoroughly before reacting hastily.

In your opinion, will the CBAM change the way companies choose non-EU suppliers over European ones?

Yes, but not immediately or automatically. I don't believe there will be a sudden return to “European only.” Rather, the CBAM will make the differences between non-EU suppliers more visible: those who are organized, transparent, and collaborative will still have a place; those who focus solely on price will struggle more.

For a distributor such as Univiti, what are the main considerations when it comes to CBAM and product traceability?

The first consideration is data quality: knowing where the product comes from, who produces it, and how it is produced. The second is not to confuse the end customer. Our role is to filter the complexity of regulations and transform them into consistent operational choices, without creating unnecessary alarmism.

Do you think that CBAM could become a natural selection factor in the market, rewarding the most organized and transparent companies?

Yes, but gradually. It will not eliminate operators overnight, but over time it will reward those who work in an orderly manner and penalize those who operate without vision. Rather than selection based on size, it will be selection based on method.

Looking ahead to the coming years, what kind of developments do you expect in the fastener market with the introduction of CBAM?

I expect greater attention to the supply chain, less improvisation, and more stable supply relationships. I don't see an immediate revolution in prices, but rather an evolution in the quality of commercial relationships and the professionalism of operators.

Do you think there is a risk that price will once again become the sole criterion for choice, but in a more disguised way?

Yes, this risk exists. Talking about CBAM or sustainability without real data can become an elegant way to return to competing solely on price. This is why transparency and consistency are needed, not just communication.

Will there be cases where full compliance with CBAM means giving up long-standing suppliers?

It is possible. Not for ideological reasons, but for practical ones. If a supplier is unwilling to share minimum data or improve its processes, it will become difficult to continue working together over time.

Do you think that in the future, the ability to manage regulations such as CBAM will become part of a supplier's perceived value?

Absolutely yes. Just as we take logistics or administrative quality for granted today, tomorrow it will be normal to expect regulatory expertise. It will not be a competitive advantage, but a prerequisite.

In five years' time, looking back, will the CBAM be remembered as an obstacle or a turning point?

Probably as a turning point. Not because it changed everything, but because it accelerated a process that was already underway: the move towards more conscious, less opaque, and more professional supply chains.

Transparency, method, and competitiveness

The CBAM not only introduces new obligations, but also highlights a transformation already underway in the industrial world: a shift towards more transparent supply chains, more structured data, and supply relationships based on method and reliability, not just price. In this scenario, the regulation becomes an accelerator of awareness, rather than a simple constraint to be managed.
As the interview also shows, the real impact of the CBAM will not be immediate or uniform, but progressive. It will affect the way companies read the market, select partners, and build their positioning over time. Those who are able to tackle this change with a pragmatic approach, vision, and adaptability will not only comply, but will be able to transform regulatory complexity into an element of solidity and credibility. This is because, increasingly, the future of industry will depend on the ability to combine competitiveness, transparency, and responsibility throughout the supply chain.