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Full CBAM Enforcement from January 2026: What Changes for SA Exporters

January 1, 2026 marked the beginning of full CBAM enforcement. Financial payments are now required. This guide explains what has changed and what SA exporters must do immediately.

Full CBAM Enforcement from January 2026: What Changes for SA Exporters

January 1, 2026 was a watershed date for South African exporters. The CBAM transitional phase ended, and full enforcement began. EU importers of CBAM-covered goods are now legally required to purchase and surrender CBAM certificates — and the financial stakes are significant.

What Has Changed

| Before January 1, 2026 | From January 1, 2026 | |------------------------|----------------------| | Quarterly reporting only | Annual CBAM declarations required | | No financial payments | CBAM certificates must be purchased | | Penalties limited to reporting failures | Penalties of EUR 100/tCO₂ for non-compliance | | Default values widely accepted | Actual data increasingly required |

The Certificate Surrender Calendar

Under full enforcement, the CBAM compliance calendar is:

| Date | Requirement | |------|-------------| | Throughout 2026 | Purchase CBAM certificates as goods are imported | | By March 31, 2027 | Submit annual CBAM declaration for 2026 imports | | By September 30, 2027 | Surrender CBAM certificates equal to 2026 embedded emissions | | By September 30, 2028 | Surrender certificates for 2027 imports |

The September 30, 2027 deadline is the first major financial reckoning for EU importers of SA goods.

The Financial Stakes

For a South African steel exporter shipping 100,000 tonnes to the EU annually:

| Calculation | Value | |-------------|-------| | Export volume | 100,000 tonnes | | Embedded carbon (default) | 2.18 tCO₂/tonne | | Total embedded emissions | 218,000 tCO₂ | | CBAM certificate price | EUR 65.42/tCO₂ | | Gross CBAM liability | EUR 14,261,560 | | SA carbon tax credit | EUR 2,509,658.537 | | Net CBAM liability | EUR 11,751,901.463 |

This is a real cost that will be reflected in the price EU importers are willing to pay for SA goods.

What SA Exporters Must Do Now

  1. ▸Confirm your EU customers are registered as Authorised CBAM Declarants
  2. ▸Provide embedded carbon documentation — actual data or confirmation that EU defaults apply
  3. ▸Claim SA carbon tax credits — ensure SARS certificates are available
  4. ▸Register your operations at the Digital Product Passport Registry

CBAM is not a future requirement — it is live now. As of January 1, 2026, South African exporters shipping goods above 50 tonnes to the EU must have a Carbon Border Adjustment declaration or their shipment will be blocked. This is Gate 2 of 3. Complete your KYC identity verification first, then return here to understand your CBAM obligations, then register at the Digital Product Passport Registry to complete all three gates in one place.

Frequently Asked Questions

What changed on January 1, 2026 for CBAM?
From January 1, 2026, EU importers of CBAM-covered goods must purchase CBAM certificates equal to the embedded emissions in their imports. The transitional phase (reporting only) ended on December 31, 2025. Financial payments are now mandatory.
When is the first CBAM certificate surrender deadline?
The first CBAM certificate surrender deadline is September 30, 2027, covering all CBAM-covered imports during 2026. EU importers must purchase and surrender certificates equal to the embedded emissions in their 2026 imports by this date.
What is the penalty for missing the September 30, 2027 deadline?
The penalty for failing to surrender sufficient CBAM certificates by the deadline is EUR 100 per tonne of unreported embedded emissions. For a large steel importer, this could amount to tens of millions of euros.
Do SA exporters need to do anything differently from January 2026?
SA exporters do not directly purchase CBAM certificates, but they need to ensure their EU customers have the embedded carbon data they need to comply. If you have not yet provided your EU customers with CBAM-ready embedded carbon documentation, do so immediately.
What is the CBAM certificate price?
CBAM certificate prices are set weekly based on the average closing price of EU ETS allowances in the preceding week. As of April 2026, the EU ETS price is approximately EUR 65/tCO₂, meaning CBAM certificates cost approximately EUR 65 per tonne of embedded CO₂.
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