Navigating the EU’s new CBAM law for packaging

If you import more than 50 tonnes of aluminium and/or steel product into the EU, the Carbon Border Adjustment Mechanism (CBAM) is now a live compliance requirement – with aluminium and steel packaging covered alongside cement, fertilisers, hydrogen and electricity.

From 2026, you must collect data from your supply chain, calculate the carbon emissions, submit data to the authorities, and if necessary pay the appropriate fees.

This ensures that your goods flow smoothly across the border and you pay the right taxes.

The commercial impact

CBAM exists to put a fair price on high carbon, low-cost production – encouraging cleaner industrial production outside of the EU. If your suppliers have a high carbon footprint, you and your customers will ultimately be paying higher taxes.

If credible data isn’t available, importers may have to rely on less favourable approaches, including higher default values. Even if you’re not the EU “importer of record”, your customers will increasingly require supporting evidence to ensure their goods reach the destination without delay or penalty by the authorities.

Even if you’re not the EU “importer of record”, your customers will increasingly require supporting evidence to ensure their goods reach the destination without delay or penalty by the authorities.

Don’t be caught out by unexpected costs

It takes time to collect data from several layers deep within your supply chain, as you need to go all the way back to the primary smelting. Where information is not available, you are risking penalties, interrupting deliveries, or paying a higher default price.

Although the first declarations are not due until autumn 2027, proper cost planning will help avoid disruption and unexpected costs down the line.

CBAM authorisation

If you do nothing else, and you think you are affected, you must first register with the authorities before 31 March 2026 (click here).

If you do nothing else – and think you are affected – you must register with the authorities before 31st March 2026

How CarbonQuota can support aluminium and steel packaging providers

CarbonQuota helps you build a repeatable, audit-ready approach to carbon data – so you can respond to CBAM-driven requests confidently.

  • Supplier engagement support to obtain the right data.
  • Data gathering and communication templates.
  • Calculate carbon emissions, with a clear process.
  • Create an evidence pack for your customers: methodologies, data sources, emission factors, and traceable outputs.
  • Ongoing reporting readiness: move from one-off calculations to a process you can maintain quarter after quarter.

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