EU CBAM Goes Live: What It Means for the Semiconductor Supply Chain

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CBAM entered its definitive phase in January 2026. Finished semiconductors are not a directly regulated product yet, but the EU is widening the scope to downstream goods, so the semiconductor supply chain is coming within range of requests for carbon data. This piece sets out what has changed from a supplier's point of view and what you should be preparing now.

What CBAM is

CBAM (the Carbon Border Adjustment Mechanism) makes high-carbon products imported into the EU carry a carbon cost at the same level as production inside the EU. Its purpose is to prevent carbon leakage — to stop companies moving production outside the bloc to escape regulation, and to put producers inside and outside the EU on a level competitive footing.

What has changed now: from the transitional period to the definitive period

From October 2023 to the end of 2025 it was a transitional period, with reporting only and no cost attached. From 1 January 2026 it moves to the definitive period, in which importers must, on top of reporting, buy and surrender CBAM certificates matching their emissions. The reporting cycle also changes from quarterly to once a year, and third-party verification has become mandatory.

The dates that matter in practice — the first annual declaration and certificate surrender for goods imported in 2026 fall due on 30 September 2027, and certificate sales begin on 1 February 2027. In other words, the cost of 2026 imports is only fixed in 2027, but the data collection has to happen from now.

At a glance: the CBAM timeline

Roadmap · The CBAM timeline by phase — based on the European Commission's implementing regulations

Transitional period

Emissions reporting

2023.10 ~ 2025.12

No cost attached

Definitive period

Reporting + buying and surrendering certificates + third-party verification

2026.1 ~

Obligations begin

First surrender deadline

Annual declaration and certificate surrender for 2026 imports

2027.9.30

Certificate sales start on 2027.2.1

1. 1

   Transitional period

   2023.10 ~ 2025.12

   Emissions reporting

   No cost attached

2. 2

   Definitive period

   2026.1 ~

   Reporting + buying and surrendering certificates + third-party verification

   Obligations begin

3. 3

   First surrender deadline

   2027.9.30

   Annual declaration and certificate surrender for 2026 imports

   Certificate sales start on 2027.2.1

The goods covered today, and where the scope is heading

The goods directly covered today are cement, steel, aluminium, fertilisers, electricity and hydrogen — six items. Finished semiconductors are not directly covered. The EU has, however, proposed extending the scope to downstream products with a high steel or aluminium content, and is considering bringing further goods in. Where semiconductor equipment, parts and structures contain steel or aluminium, they can be drawn into range indirectly.

What a semiconductor supplier should prepare now

The core of it is putting in place a system that can work out product-level carbon emissions data at the level of the process and the individual installation. CBAM asks for measured data per production installation, not a company average or a regional emission factor. This sits on the same foundation as answering RE100 and EcoVadis.

1. Put in place a system that organises electricity use and emissions data by site and by process
2. Review the routes for lowering indirect emissions by switching to renewable energy (green premium, REC, PPA)
3. Prepare in advance the response format for the product carbon data your client, the company exporting to the EU, will ask for

Corporate Energy Transition Center — our view

For a semiconductor supplier, CBAM is an easy subject to put off as something that is not your problem yet. But CBAM, RE100 and EcoVadis end up asking for the same data. Organise your electricity and emissions data by site properly once, and you can answer all three at the same time. What you prepare now decides how quickly you can respond when client requirements arrive in earnest.

• [Source: Carbon Border Adjustment Mechanism (EU Commission, DG TAXUD)]
• [Source: CBAM Simplification Regulation (EU) 2025/2083 · European Commission implementing regulation package (2025.12), checked 2026.6.27]

Note: CBAM rules may change through implementing regulations and the extension to downstream goods, so please check the latest official European Commission text when you act on this.