01 January 2026
From 1 January 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) moves into its definitive phase. For many in the wire and cable industry, this marks a fundamental change in […]
From 1 January 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) moves into its definitive phase. For many in the wire and cable industry, this marks a fundamental change in how steel and aluminium inputs are priced, reported and traded into the EU.
What began as an emissions reporting exercise will become a real financial obligation at the EU border – with direct implications for cost, compliance and competitiveness.
This article outlines what CBAM means in practice and the key actions IWMA members should be taking now.
What Is Changing in 2026?
During the transitional phase (2023-2025), CBAM required importers to report embedded emissions only.
From 2026:
CBAM initially applies to steel and aluminium, making it particularly relevant to:
Who Is Affected?
EU Manufacturers
Even where production is based in the EU, CBAM matters if:
Non-EU Exporters Supplying the EU
CBAM represents a direct market-access requirement.
Without emissions data and compliance readiness, exporters risk:
Key Risks for Wire & Cable Businesses
What Members Should Be Doing Now
Identify:
Action: map CBAM exposure by product, supplier and market.
From 2026, verified emissions data is essential.
Action: prioritise suppliers with transparent, auditable data.
Many contracts signed before CBAM do not account for carbon costs.
Action: update commercial terms before renewal cycles.
CBAM will operate alongside:
Action: extend due diligence beyond Tier-1 suppliers.
CBAM is not just a cost – it is a signal of where EU policy is heading.
Businesses that are:
will be better placed for:
CBAM and Long-Lead Projects
For HVDC, subsea and major grid projects, CBAM presents additional risk due to:
Early engagement with EPCs and customers to clarify:
will be critical.
Key Message for Members
CBAM is not a temporary measure — it is a permanent change to how the EU trades.
Members who act early will protect margins, reduce border risk and strengthen their competitive position. Those who delay risk discovering CBAM only when shipments reach the border.
IWMA will continue to support members with guidance and insight as CBAM and wider trade policy evolve.
CBAM 2026 Readiness Checklist
A practical guide for wire & cable businesses
Use this checklist to assess whether your business is prepared for CBAM’s cost-bearing phase from 1 January 2026.
☐ Identified all products and inputs covered by CBAM
☐ Mapped where steel and aluminium enter your supply chain
☐ Confirmed whether you are the CBAM declarant or reliant on a customer/importer
☐ Assessed exposure by market (EU vs non-EU sales)
☐ Requested embedded emissions data from all relevant suppliers
☐ Confirmed data methodology (actual vs estimated)
☐ Identified suppliers unable or unwilling to provide verified data
☐ Avoided reliance on default CBAM values
☐ Reviewed existing contracts for CBAM cost exposure
☐ Added CBAM or regulatory cost pass-through clauses where possible
☐ Assessed fixed-price and long-term project risk
☐ Updated pricing models to reflect carbon intensity
☐ Assigned CBAM responsibility internally (finance / compliance / supply chain)
☐ Established internal CBAM reporting and documentation processes
☐ Aligned procurement, sales and finance teams on CBAM impacts
☐ Ensured record-keeping meets audit expectations
☐ Extended due diligence beyond Tier-1 suppliers
☐ Reviewed suppliers for forced-labour and sanctions exposure
☐ Documented traceability for CBAM-relevant inputs
☐ Integrated compliance into supplier selection criteria
☐ Confirmed documentation required at EU border
☐ Allowed for potential border delays in delivery schedules
☐ Reviewed Incoterms and risk allocation
☐ Built CBAM compliance into logistics planning
☐ Identified opportunities to shift to lower-carbon materials
☐ Used CBAM readiness as a sales and tender differentiator
☐ Engaged customers early on CBAM cost implications
☐ Factored CBAM into 2026–27 investment planning
For HVDC & Long-Lead Projects
☐ Clarified CBAM responsibility with EPCs and TSOs
☐ Built CBAM cost assumptions into project pricing
☐ Addressed carbon risk in contracts signed pre-2026
☐ Engaged early on compliance and documentation requirements
Final Check
☐ CBAM readiness reviewed at board or senior management level
☐ 2026 action plan agreed and resourced
Key Reminder
CBAM will be enforced at the border – preparation in advance is the only way to avoid disruption.
IWMA will continue to share updates, guidance and best practice as CBAM implementation progresses.