CBAM: learning from the KPMG event

CIF attended KPMG’s September briefing on the EU Carbon Border Adjustment Mechanism, or CBAM.

The topic is increasingly relevant to construction supply chains as the mechanism moves from transitional reporting into its definitive phase, which began on 1 January 2026.

CBAM covers specified imported goods, including categories of cement, iron and steel, and aluminium. It is not a blanket charge on all construction materials. The position depends on the goods’ classification and origin and the applicable rules and exemptions.

Construction firms should understand whether they are the importer or a downstream purchaser. Importers need to establish their obligations, gather reliable supplier and embedded-emissions information and maintain appropriate records. Purchasers should discuss potential cost and data implications with suppliers, particularly where contracts extend across reporting periods.

EPA guidance confirms that the first annual CBAM declaration, covering 2026 imports, is due by 30 September 2027. The corresponding certificate obligations make early preparation important. Mapping relevant imports, assigning responsibility and checking commodity codes and supplier information are useful starting points.

KPMG: understanding CBAM

EPA guidance on the annual CBAM declaration