CBAM Working Capital for EU Importers in 2026

The EU Carbon Border Adjustment Mechanism, or CBAM, has moved from a reporting exercise to a commercial issue for importers.

From 1 January 2026, EU importers of covered goods above the applicable threshold need to be registered as authorised CBAM declarants, or hold an application reference number. Covered sectors include iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The next major deadline is 30 September 2027, when importers must submit their first declaration and surrender the corresponding CBAM certificates. The European Commission’s CBAM guidance sets out the current operational requirements.

For many businesses, the challenge is not only compliance. It is working capital.

CBAM creates a new import cost

CBAM requires importers to account for the embedded emissions in covered goods brought into the EU. Where a carbon price has already been paid in the country of production, it may be deductible, subject to evidence and the applicable rules. Otherwise, importers must plan for the cost of CBAM certificates.

This changes the economics of purchasing carbon-intensive goods.

An importer of steel, aluminium or fertiliser may already be managing supplier prepayments, freight, customs duties, VAT, inventory costs and lengthy receivable cycles. CBAM adds another variable to the landed-cost calculation: the cost of carbon embedded in the imported product.

The cost will vary depending on the product, supplier, origin, emissions intensity and prevailing carbon price. However, the commercial result is clear. Importers need to preserve liquidity for a cost that sits alongside the physical purchase, not after the trade is complete.

The real issue is timing

Importers are rarely paid immediately by their customers. A distributor may buy stock from a producer, pay freight and clear customs, then wait 30, 60 or 90 days to collect from its own buyers.

That delay creates the classic working-capital gap. The company has already paid suppliers and logistics providers but has not yet received sales proceeds.

CBAM can widen that gap. Even where the certificate surrender date is later than the physical import, a prudent importer should reserve liquidity from the start. It cannot assume that future sales receipts will be available when compliance obligations arise.

For businesses operating recurring import programmes, the issue compounds over time. Each new shipment adds inventory, receivables exposure and prospective CBAM cost. A company that previously needed a EUR 5 million purchasing line may need more capacity simply to maintain the same trading volume.

This is where revolving trade-finance facilities become relevant. A properly structured facility can recycle capital as goods are purchased, delivered and sold, rather than requiring the importer to fund every shipment entirely from its own balance sheet.

CBAM should be built into the capital stack

CBAM should not be treated as a separate compliance project run only by legal or sustainability teams. It should be incorporated into the company’s procurement, treasury and financing model.

A practical capital stack may include:

• a purchase facility or documentary LC for supplier payments;
• inventory finance for goods held before sale;
• receivables finance for approved customers;
• a working-capital reserve for customs, VAT, freight and CBAM exposure;
• credit insurance or other risk mitigation where appropriate.

The right mix depends on the company’s buying terms, customer concentration, commodity, shipping route and balance sheet. A business importing aluminium under long-term supply contracts may need a different structure from a trader purchasing steel on a spot basis.

The important point is that CBAM cost should be modelled alongside the physical trade, not discovered after contracts have been signed.

Companies that need to improve liquidity across the full purchase-to-sale cycle can explore trade-finance facilities against inventory and receivables.

Supplier data now has financial value

CBAM compliance depends on data from the supply chain. Importers need reliable information on the emissions embedded in their goods and, where relevant, evidence of carbon prices paid in the country of origin.

That creates a new commercial divide between suppliers.

A supplier that can provide credible, product-level emissions data may be easier to finance and more attractive to EU buyers. A supplier that cannot produce reliable information may create a higher compliance burden, a higher estimated carbon cost or an unacceptable risk of reporting errors.

Importers should therefore include CBAM data requirements in supplier onboarding, contracts and purchase orders. They should also consider whether contracts allow price adjustments where emissions data or carbon costs change materially.

This is not only an ESG issue. It is a credit issue. Lenders and trade-finance providers will increasingly want to understand the compliance position, supplier quality and cost assumptions behind an import programme.

KYT matters as much as KYC

Know Your Customer checks confirm who a counterparty is. Know Your Transaction, or KYT, tests whether the underlying deal is commercially and operationally credible.

For CBAM-affected imports, KYT should cover more than the usual purchase contract and invoice. It should assess the product classification, country of origin, supplier role, emissions-data source, shipping route, payment terms and expected buyer proceeds.

The objective is to identify problems before capital is committed. For example, a low purchase price may appear attractive until the importer discovers that the supplier cannot substantiate emissions data, the origin documentation is weak, or the expected CBAM cost has not been reflected in the margin.

Financely provides KYT in trade finance to help assess whether the transaction, documentation and financial structure are aligned before funding is arranged.

A commercial opportunity for prepared importers

CBAM will create pressure for some importers, but it can also create an advantage for prepared businesses.

Importers that understand their emissions exposure, secure supplier data early and build CBAM costs into their working-capital model can negotiate from a stronger position. They can make more informed procurement decisions, avoid surprise costs and present a more bankable case to financiers.

The best time to address the funding requirement is before a working-capital shortage limits purchasing capacity or forces a company to turn down profitable orders.

Financely helps importers structure commodity trade-finance, working-capital facilities and transaction-readiness processes around real procurement cycles. CBAM is becoming part of the cost of doing business in covered sectors. The companies that finance for it early will be better placed to protect margins and keep trading.