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Understanding the Carbon Border Adjustment Mechanism (CBAM): Implications for the U.S. Market

Author
Sebastian Marland
Publication Date
December 1, 2024

Climate change is one of the most pressing challenges of our time, prompting governments worldwide to adopt innovative strategies for reducing greenhouse gas (GHG) emissions. Among these, the European Union’s (EU) Carbon Border Adjustment Mechanism (CBAM) stands out as a transformative policy aimed at addressing carbon leakage and ensuring fair competition. As CBAM begins to take effect, its impact will extend beyond Europe, influencing global trade and creating opportunities and challenges for U.S. businesses.

What is CBAM?


CBAM is designed to align the carbon costs of imported goods with those produced within the EU. As part of the EU’s goal to cut emissions by 55% by 2030 and achieve carbon neutrality by 2050, CBAM targets carbon leakage, a phenomenon where companies move production to countries with less stringent environmental regulations. This policy ensures that imported goods reflect the cost of their carbon emissions, leveling the playing field and encouraging cleaner production globally.


How Does CBAM Work?


CBAM works alongside the EU’s Emission Trading System (EU ETS), a cap-and-trade system requiring EU companies to pay for their carbon emissions. Under CBAM:

  • Importers must report the emissions embedded in their products during the transitional phase (2023–2025).
  • From 2026, importers will need to purchase CBAM certificates tied to the EU ETS carbon price to cover the emissions of imported goods.
    This dual-phase approach gives businesses time to adapt while gradually integrating financial obligations.

Phases of Implementation

  1. Transitional Phase (2023–2025)
    Importers report embedded emissions quarterly but do not face immediate financial obligations. This phase focuses on building robust reporting mechanisms and ensuring businesses comply.
  2. Definitive Phase (Starting 2026)
    Importers will purchase CBAM certificates for the embedded carbon emissions in their goods. By 2034, CBAM will fully cover all emissions from the listed sectors, ensuring comprehensive carbon pricing.

Sectors Covered by CBAM


CBAM targets high-emission industries, including:

  • Cement
  • Iron and Steel
  • Aluminum
  • Fertilizers
  • Electricity
  • Hydrogen

These sectors face the greatest risk of carbon leakage and represent a significant share of global emissions.

CBAM-Covered Sectors and Their Carbon Emissions

Implications for the U.S. Market

  1. Increased Costs for Exporters
    U.S. exporters of CBAM-covered goods, such as steel and aluminum, will need to comply with EU reporting requirements and may face higher costs if their production processes are carbon-intensive. Investing in low-carbon technologies could mitigate these expenses and improve competitiveness.
  2. Opportunities for Clean Technologies
    CBAM incentivizes cleaner production. U.S. manufacturers already embracing renewable energy and sustainable practices can capitalize on this demand, potentially expanding market access to Europe.
  3. Policy Alignment and Global Leadership
    As CBAM sets a global precedent, the U.S. may face pressure to adopt similar carbon pricing mechanisms. Aligning policies with the EU could prevent trade tensions and position the U.S. as a leader in climate action.
  4. Supply Chain Adjustments
    U.S. businesses reliant on carbon-intensive imports may experience cost increases as CBAM drives up prices for covered goods. Diversifying supply chains and investing in greener alternatives will become essential.

Challenges and Criticisms

While CBAM is a bold step toward reducing global emissions, it faces criticism:

  • Trade Disputes: Some countries view CBAM as a protectionist measure that disadvantages their exports.
  • Complexity for Businesses: Smaller companies, particularly in developing nations, may struggle to comply with reporting and certification requirements.
  • Impact on Developing Economies: CBAM could disproportionately affect countries lacking resources to adopt greener technologies.

CBAM's Role in Driving Change

CBAM serves as a powerful tool in the fight against climate change. By encouraging global trading partners to implement stricter environmental policies, it fosters international collaboration. For the U.S., CBAM represents both a challenge and an opportunity to strengthen its renewable energy infrastructure, enhance trade relationships, and lead in sustainable production.


CBAM Timelline

The Path Forward with AFS Commodities

Navigating CBAM’s complexities requires strategic planning and expert guidance. AFS Commodities is here to help businesses adapt to these transformative policies. From compliance strategies to carbon reduction initiatives, AFS Commodities offers tailored solutions that ensure companies remain competitive in the global market.