EU Commission Begins Carbon Border Charges as Shippers Rework Tariff Strategies
The EU’s Carbon Border Adjustment Mechanism enters its charging phase, adding new costs to steel, aluminum and other imports. U.S. tariff exclusions on select China-origin goods are extended, while China adjusts 2026 import duties. Global logistics providers including DHL, Maersk and Hapag-Lloyd roll out compliance updates and surcharges.
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Executive Summary
EU CBAM charging phase starts January 1, 2026, introducing carbon-linked costs on imports of steel, aluminum and other covered goods, with EU ETS prices hovering around €70–90 per tonne in recent weeks (European Commission; Reuters).
USTR extends selected Section 301 tariff exclusions for China-origin goods into 2026, prompting importers to recalibrate sourcing and customs planning (USTR press office notices published in late December 2025).
EU Carbon Border Charges Reshape Inbound Logistics
The European Commission’s Carbon Border Adjustment Mechanism moved into its charging phase on January 1, 2026, requiring importers of cement, iron and steel, aluminum, fertilizers, electricity and hydrogen to purchase CBAM certificates linked to the EU Emissions Trading System price. This effectively adds a variable cost to covered consignments, with certificate prices typically tracking recent EU ETS levels of roughly €70–90 per tonne, according to market reporting (European Commission CBAM overview; Reuters carbon price coverage).
Logistics operators have begun recalibrating routings and landed-cost estimates. Import/export teams at manufacturers are updating supplier declarations to reflect embedded emissions data, a prerequisite for CBAM reporting. Freight forwarders and customs brokers say importers are shifting some orders among suppliers where emissions intensity is lower to minimize CBAM certificate purchases (DHL regulatory update on CBAM; Hapag-Lloyd CBAM advisories).
Carriers and Forwarders Adjust Fees and Compliance Tools
Global logistics providers are introducing administrative fees and digital tools to meet CBAM documentation standards. DHL has published CBAM guidance summarizing affected commodity codes, timelines and documentary obligations for importers, noting that additional brokerage time may be required at EU entry points (DHL customs regulatory updates). Maersk has directed customers to emissions reporting resources and advised on supply chain adjustments needed for the CBAM charge phase (Maersk customer news).
Meanwhile, Hapag-Lloyd has circulated regulatory advisories detailing CBAM workflow impacts on import declarations and data capture for covered shipments. Multi-national importers working with UPS and other integrated carriers are updating landed-cost calculators to incorporate potential CBAM certificate costs, alongside existing customs duty and VAT estimates (Hapag-Lloyd customer information; UPS international tools).
Selected Trade and Tariff Moves Late 2025–Early 2026
In late December 2025, the Office of the U.S. Trade Representative extended select Section 301 tariff exclusions for China-origin goods into 2026, a decision welcomed by importers of industrial components and medical supplies who faced renewed duty exposure. While exclusions are narrow, logistics managers say the action reduces near-term landed-cost volatility for specific HS lines (USTR press office). Concurrently, China’s Ministry of Finance announced annual tariff adjustments effective January 1, 2026, fine-tuning MFN and provisional rates across targeted product categories (China MOF; Reuters).
These moves arrive as the EU’s CBAM costs begin to influence sourcing decisions for steel and aluminum, nudging some buyers to evaluate suppliers with lower emissions intensity or consider alternative production hubs. Industry analysts say cross-border procurement strategies are increasingly blending traditional tariff analysis with carbon-cost modeling, particularly for metal-intensive sectors entering the EU (European Commission; McKinsey supply chain insights).
Key Cross-Border Measures and Logistics Implications
{{INFOGRAPHIC_IMAGE}}Operational Implications and Next Steps
Compliance teams are integrating CBAM certificate pricing into landed-cost models and recalibrating Incoterms and contract terms where needed. The updated 2026 Harmonized Tariff Schedule published by the U.S. International Trade Commission is also prompting classification reviews, ensuring import entries reflect current statistical annotations to avoid clearance delays (USITC HTS). For more on related Logistics developments.
Trade managers are revisiting supplier scorecards to factor in emissions intensity alongside tariff impacts, especially for EU-bound steel and aluminum programs. Large forwarders and carriers are expanding digital tools to streamline CBAM declarations, while importers affected by U.S. exclusion extensions are maintaining documentation to demonstrate eligibility and duty-free status on covered lines (DHL CBAM guidance; USTR press office). This builds on broader Logistics trends of embedding sustainability and regulatory costs into procurement decisions.
FAQs
{
"question": "How does the EU’s CBAM affect landed costs for steel and aluminum imports?",
"answer": "CBAM requires importers to purchase certificates reflecting embedded emissions in covered goods, with certificate prices linked to EU ETS levels. In early January 2026, EU carbon prices have generally traded around €70–90 per tonne, which importers translate into incremental costs per shipment based on product-specific emissions. Logistics teams must collect emissions data from suppliers and align reporting to customs entries. Carriers such as DHL and Hapag-Lloyd provide advisory services to streamline these processes."
}
{
"question": "What did the USTR change regarding Section 301 tariffs on China-origin goods?",
"answer": "In late December 2025, USTR extended select tariff exclusions on specific China-origin products into 2026. These exclusions reduce or eliminate duties on covered HS lines, easing cost pressure for importers of industrial components and medical supplies. While the scope is limited, the extension stabilizes landed costs for eligible shipments. Importers should verify product eligibility against published exclusion lists and maintain documentation for customs clearance."
}
{
"question": "How are logistics companies responding to CBAM from an operational standpoint?",
"answer": "Carriers and forwarders are rolling out administrative fees and digital workflows to capture emissions data and support CBAM reporting. DHL’s customs regulatory update outlines document requirements and timelines, while Maersk has directed customers to emissions reporting tools and best practices. Hapag-Lloyd’s customer advisories detail CBAM-related import declaration changes. These adjustments help importers avoid delays and ensure CBAM certificate purchasing aligns with shipment profiles and supplier emissions."
}
{
"question": "What are the implications of China’s 2026 tariff adjustments for supply chains?",
"answer": "China’s 2026 tariff adjustments, effective January 1, refine MFN and provisional rates across select product categories. For importers, these changes can alter sourcing economics, particularly in consumer and strategic industrial segments. The Ministry of Finance’s notice guides traders on updated duty rates. Combined with EU CBAM and U.S. exclusion extensions, multinational supply chains are rebalancing supplier portfolios and revisiting landed-cost models to maintain margins."
}
{
"question": "What should importers prioritize in Q1 2026 to manage tariff and CBAM risk?",
"answer": "Importers should update HS classifications aligned with the USITC’s 2026 HTS, secure supplier emissions data for CBAM declarations, and integrate variable CBAM certificate prices into landed-cost models. They should verify eligibility for USTR’s extended exclusions and adjust contracts to reflect carbon-linked costs and compliance workflows. Working with carriers such as UPS and DHL to standardize documentation can reduce clearance delays and mitigate unexpected charges at EU borders."
}
References
How does the EU’s CBAM affect landed costs for steel and aluminum imports?
CBAM requires importers to purchase certificates reflecting embedded emissions in covered goods, with certificate prices linked to EU ETS levels. In early January 2026, EU carbon prices have generally traded around €70–90 per tonne, which importers translate into incremental costs per shipment based on product-specific emissions. Logistics teams must collect emissions data from suppliers and align reporting to customs entries. Carriers such as DHL and Hapag-Lloyd provide advisory services to streamline these processes.
What did the USTR change regarding Section 301 tariffs on China-origin goods?
In late December 2025, USTR extended select tariff exclusions on specific China-origin products into 2026. These exclusions reduce or eliminate duties on covered HS lines, easing cost pressure for importers of industrial components and medical supplies. While the scope is limited, the extension stabilizes landed costs for eligible shipments. Importers should verify product eligibility against published exclusion lists and maintain documentation for customs clearance.
How are logistics companies responding to CBAM from an operational standpoint?
Carriers and forwarders are rolling out administrative fees and digital workflows to capture emissions data and support CBAM reporting. DHL’s customs regulatory update outlines document requirements and timelines, while Maersk has directed customers to emissions reporting tools and best practices. Hapag-Lloyd’s customer advisories detail CBAM-related import declaration changes. These adjustments help importers avoid delays and ensure CBAM certificate purchasing aligns with shipment profiles and supplier emissions.
What are the implications of China’s 2026 tariff adjustments for supply chains?
China’s 2026 tariff adjustments, effective January 1, refine MFN and provisional rates across select product categories. For importers, these changes can alter sourcing economics, particularly in consumer and strategic industrial segments. The Ministry of Finance’s notice guides traders on updated duty rates. Combined with EU CBAM and U.S. exclusion extensions, multinational supply chains are rebalancing supplier portfolios and revisiting landed-cost models to maintain margins.
What should importers prioritize in Q1 2026 to manage tariff and CBAM risk?
Importers should update HS classifications aligned with the USITC’s 2026 HTS, secure supplier emissions data for CBAM declarations, and integrate variable CBAM certificate prices into landed-cost models. They should verify eligibility for USTR’s extended exclusions and adjust contracts to reflect carbon-linked costs and compliance workflows. Working with carriers such as UPS and DHL to standardize documentation can reduce clearance delays and mitigate unexpected charges at EU borders.
