The CBAM Transitional Phase (2023–2025): What SA Exporters Reported

The CBAM transitional phase ran from October 2023 to December 2025. During this period, EU importers submitted quarterly reports on embedded carbon — with no financial payments required. This article explains what was reported and what changed in 2026.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

The CBAM Transitional Phase: Building the Data Infrastructure

The Carbon Border Adjustment Mechanism was introduced in two phases. The transitional phase (October 1, 2023 — December 31, 2025) was a learning and preparation period. The full enforcement phase (from January 1, 2026) is when financial payments became mandatory.

Understanding the transitional phase helps SA exporters appreciate what data was collected, what gaps were identified, and what the full enforcement phase requires.

What the Transitional Phase Required

During the transitional phase, EU importers of covered goods were required to submit quarterly reports to the EU CBAM Registry. These reports covered:

▸The CN codes and quantities of covered goods imported in the quarter
▸The country of origin of each covered good
▸The embedded carbon of each covered good (actual or EU default)
▸The carbon price paid in the country of origin (if any)

Critically, no financial payments were required during the transitional phase. EU importers did not need to purchase CBAM certificates. The purpose was to build the data infrastructure and test the reporting system.

The Default Values Problem

A significant finding from the transitional phase was that many EU importers were using EU default emission values rather than actual data from their SA suppliers. EU default values are set conservatively high — they represent the average emission intensity of EU production for each covered sector, which is typically lower than SA production due to the EU's cleaner electricity grid.

For SA exporters, this means:

▸EU buyers using default values face higher CBAM certificate costs
▸Higher CBAM costs create commercial pressure on SA exporters (buyers demand price reductions or switch to lower-carbon suppliers)
▸SA exporters who provide verified actual data give their buyers a competitive advantage

The Transition to Full Enforcement

From January 1, 2026, the quarterly reporting requirement was replaced by an annual compliance cycle:

Throughout 2026: EU importers purchase CBAM certificates as they import covered goods.

By May 31, 2027: EU importers submit their annual CBAM declaration for 2026 imports.

By September 30, 2027: EU importers surrender CBAM certificates equal to the total embedded carbon of their 2026 covered imports.

This is the first financial deadline under full CBAM enforcement. SA exporters who have not yet provided verified embedded carbon data to their EU buyers should do so urgently — the September 2027 deadline is approaching.

What SA Exporters Should Do Now

The transitional phase is over. Full enforcement is live. SA exporters should:

▸
Measure your embedded carbon: Calculate your Scope 1 and Scope 2 emissions per tonne of product using the methodology in the EU CBAM Implementing Regulation.
▸
Get third-party verification: Have your embedded carbon data verified by an accredited third-party verifier. Unverified data may be rejected by EU CBAM declarants.
▸
Register at the DPP Registry: The Digital Product Passport Registry provides SA exporters with a verified carbon report in the EU CBAM Registry submission format.
▸
Provide documentation to EU buyers: Share your verified carbon data and SA carbon tax payment evidence with your EU buyers before their May 2027 declaration deadline.

For a complete CBAM compliance registration pathway, visit the Digital Product Passport Registry.

Frequently Asked Questions

What was the CBAM transitional phase?

The CBAM transitional phase ran from October 1, 2023 to December 31, 2025. During this period, EU importers of covered goods were required to submit quarterly reports on the embedded carbon of their imports — but no financial payments (CBAM certificate purchases) were required. The transitional phase was designed to allow importers and their suppliers to build the data infrastructure needed for full compliance.

What happened after the transitional phase ended?

Full CBAM enforcement began on January 1, 2026. From this date, EU importers must purchase CBAM certificates equal to the embedded carbon of their covered imports. The first annual CBAM declaration (covering 2026 imports) must be submitted by May 31, 2027, with CBAM certificates surrendered by September 30, 2027.

Did SA exporters need to do anything during the transitional phase?

SA exporters were not directly obligated under the transitional phase — the reporting obligation fell on EU importers. However, SA exporters whose EU buyers were submitting quarterly reports needed to provide embedded carbon data to their buyers. Exporters who did not provide data had their buyers default to EU default values, which are higher than SA actuals.

What data was collected during the transitional phase?

EU importers submitted quarterly reports covering: the CN code and quantity of covered goods imported, the country of origin, the embedded carbon (either actual from the SA exporter or EU default values), and the carbon price paid in the country of origin. This data built the baseline for the full enforcement phase.

What lessons did SA exporters learn from the transitional phase?

The transitional phase revealed that many SA exporters were unprepared to provide verified embedded carbon data to their EU buyers. Exporters who could not provide actual data had their buyers use EU default values — which are significantly higher than SA actuals and increase the CBAM certificate cost. The lesson: SA exporters who invest in carbon measurement and verification have a direct commercial advantage.

Gate 3 — Complete Registration

✓ Gate 1 KYC · ✓ Gate 2 CBAM · Gate 3 DPP →

Digital Product Passport Registry

Complete all three compliance gates — Gate 1 KYC identity verification, Gate 2 CBAM financial authorisation, and Gate 3 Digital Product Passport registration — in one place at the DPP Registry.

Start Three Gates Registration →