Complete Guide to CBAM Tax 2026: What Romanian Steel and Aluminum Importers Really Pay

The Carbon Border Adjustment Mechanism (CBAM) adds a new layer of financial complexity to any import of targeted products. Starting in 2026, in addition to the price of the goods, the cost of transport and the standard customs duties, there is an obligation to purchase certificates that reflect the carbon emissions generated during production.

The price of a CBAM certificate is directly linked to the average quarterly price of EUA certificates in the EU ETS system, which in the first quarter of 2026 fluctuated in the area of 80–90 EUR per tonne of CO2. The final cost of a shipment arriving at customs is determined by several factors:

When a container of rolled steel from Turkey or aluminum from Serbia arrives at the port of Constanta, the total cost is significantly higher than what the commercial invoice shows. On a recurring import, where the covered products represent a significant portion of the volume, the effect is quickly seen in the procurement budget. On a sporadic import, the financial effect is more diluted, but still needs to be managed administratively. In both situations, ignoring CBAM is not an option.

The market does not react identically to CBAM. There is no "general price increase" equal for all categories and all suppliers — and this distinction is essential for procurement teams.

Country of origin matters decisively. An importer working with suppliers from countries with their own carbon pricing systems (UK, Norway, Switzerland) can benefit from partial deductions of the certificate cost. In contrast, an operator buying from Turkey, China, India or Ukraine does not have this possibility and bears the full cost.

Exception of the 50-ton threshold. Omnibus Regulation 2025/2083 introduced a major facility: imports below the threshold of 50 tons per year per importer are exempted from the obligation to purchase certificates. This completely changes the calculation for small players or for companies with occasional imports.

The key question is not just economic, but contractual and operational. In practice, the cost can be partially or fully absorbed by one of the three levels of the commercial chain.

1. The external supplier is most often reluctant to take on the cost. Producers in countries without their own carbon pricing system do not have a mechanism to reflect CBAM in their price. Many refuse to provide verified emissions data, which forces the importer to use inflated default values — higher than the real cost. If the pressure continues, the importer either asks for verified data, or renegotiates the price, or seeks alternative suppliers from more CBAM-friendly countries.

2. The direct importer acts as an operational and commercial buffer. It does not simply take an increase and throw it in the customer's bill, but tries to find a balance between cost, predictability and market position. The role of an experienced logistics partner becomes relevant precisely at this point: an approach based on operational clarifications, the correct collection of data from suppliers and the correct setting of expectations makes discussions about CBAM obligations more rational and easier to manage. In this context, Crystal Logistics Services can support import teams in organizing administrative flows and in obtaining the necessary visibility into the total logistics cost.

3. The end customer pays the cost, directly or indirectly. If a persistent additional cost enters the chain, part inevitably reaches the end customer — either in the form of a higher selling price or in the form of lower commercial margins on distribution. Often, the question is not if they pay, but when they pay and in what proportion.

If an annual contract was considered finalized once the price and delivery terms were signed, CBAM transforms this process. For each batch entering the country, the importer must obtain, verify and store emissions data, contract an accredited verifier and prepare the consolidated annual declaration for submission in 2027.
Contracts for 2026 must include specific clauses, without which the importer remains exposed:

• Obligation of the supplier to deliver verified emissions data for each batch.
• Price adjustment mechanism depending on the fluctuation of the EUA price.
• Clear establishment of financial liability in case increased default values are applied due to lack of data.
  The absence of these clauses in a contract signed in 2025 means that the importer bears the difference alone — with no contractual basis to transfer it to the supplier.

The price of the CBAM certificate is important, but the real effect depends on the administrative and operational discipline. Companies lose more due to process errors than due to the price of the EUA itself:

WARNING — CBAM ADMINISTRATIVE RISKS

• Lack of Authorized CBAM Declarant status obtained on time
• Missing or unreliable emissions data from the supplier
• Incorrect product classification for CN/HS classification
• Late verification documents or issued by non-accredited auditors
• Contracts without price adjustment clauses
• Poor predictability of import volumes from one month to the next
  In other words, a reasonable CBAM cost becomes much harder to absorb in a disordered procurement chain. Companies that manage their supplier and shipper relationships well do not focus only on "how much does the certificate cost", but on "what control do we have over the data and processes surrounding the import".