European Carbon Tax: What Does It Mean for Swiss Companies?

European Carbon Tax: What Does It Mean for Swiss Companies?

The European Union's Carbon Border Adjustment Mechanism (CBAM) is now fully operational as of 1 January 2026, marking a major shift in how carbon-intensive imports into the EU are regulated. After a transition period of reporting-only obligations that ran from 1 October 2023 to 31 December 2025, CBAM now requires importers to purchase and surrender "CBAM certificates" corresponding to the embedded production emissions in their goods.

The affected product categories include cement, electricity, fertilisers, iron, steel, aluminium, and hydrogen. In its first week of full operation, over 10,000 declarations were submitted by more than 4,100 authorised declarants, with iron and steel accounting for 98% of import volumes. Top exporting countries include Turkey, China, India, Canada, Taiwan, and Vietnam.

Key Rules Under the Full Compliance Phase

• CBAM certificates: EU importers must purchase certificates at a price linked to the EU Emissions Trading System (ETS) carbon price. For 2026, pricing is based on the quarterly average of EU ETS closing prices; from 2027, weekly average auction prices will apply.
• Annual declaration deadline: Moved to 30 September each year (previously 31 May). The first full declaration is due 30 September 2027 for financial year 2026.
• Quarterly coverage: From 2027, importers must surrender certificates covering 50% of embedded emissions at the end of each quarter.
• Central platform: A common EU-wide platform for certificate sales launches 1 February 2027.

Simplification for Smaller Importers

Regulation (EU) 2025/2083, adopted in October 2025, introduced a de minimis mass threshold to reduce the burden on smaller importers:

• 50 tonnes cumulative net mass per importer per calendar year for iron/steel, aluminium, fertilisers, and cement
• Does not apply to electricity or hydrogen
• If the threshold is exceeded, full CBAM obligations apply to all emissions for that calendar year
• The Commission reviews this threshold annually by 30 April and may adjust it via delegated acts if the deviation exceeds 15 tonnes

A per-consignment exemption of €150 also applies (Article 2(3), referencing Regulation 1186/2009).

Proposed Scope Expansion

The European Commission has proposed extending CBAM to approximately 180 downstream aluminium and steel-intensive products, with a proposed effective date of 1 January 2028. A comprehensive CBAM revision—including default values and potential further scope expansion—is expected by 31 December 2027.

What This Means for Swiss Companies

All Swiss enterprises handling CBAM-covered goods for the European market face direct or indirect impacts. Companies exporting these products to EU customers must be prepared to provide accurate emissions data for their production processes. Even companies below the de minimis threshold should track their annual import volumes carefully, as exceeding 50 tonnes in a calendar year triggers full CBAM obligations retroactively for all emissions that year.

Swiss companies should:

• Map which of their products fall under CBAM categories (Annex I of Regulation 2023/956)
• Implement systems to measure and report embedded carbon emissions accurately
• Understand the de minimis thresholds and monitor cumulative import volumes
• Prepare for the proposed scope expansion to downstream products in 2028
• Consider how CBAM costs may affect pricing and competitiveness in EU markets

How Positive Organizations Can Help

At Positive Organizations, we help Swiss companies understand and prepare for CBAM compliance. Whether you need support with carbon emissions measurement, CBAM certificate obligations, or strategic planning for the evolving regulatory landscape, our team can guide you through the complexities of Europe's carbon border tax.

Looking for expert guidance? Explore our ESG Compliance, Regulations and Policies and Sustainability Strategy services to take the next step.

In collaboration with Camera Commercio Cantone Ticino