Information on the current status and implementation of the CBAM Regulation (EU) 2023/956 of the European Union

Dear Sir or Madam,

With the start of 2026, the Carbon Border Adjustment Mechanism (CBAM) introduced by the European Commission has moved from the transitional phase into the implementation phase.

As an importer of affected goods – in particular steel fasteners – we are required to purchase CBAM certificates going forward, based on the CO₂ emissions generated in the country of origin. The purpose of this regulation is to prevent competitive distortions vis-à-vis European manufacturers resulting from the tightened CO₂ pricing under the EU Emissions Trading System.

The actual purchase of certificates is not expected to be possible until spring 2027. However, certificates must be procured retroactively for all imports made in 2026. This means that the resulting costs must already be factored into our calculations today, and corresponding financial provisions must be made.

In addition, the EU benchmark values and updated default values published shortly before year-end have led to a significant increase in the emission values to be applied. Using actual manufacturer-specific values is currently not yet possible, as this requires external validation, for which the institutional framework will not be established by the EU until the third quarter of 2026 at the earliest.

Based on the applicable implementing provisions, we have identified all affected items and determined the required adjustments by tariff code, weight and country of procurement, in accordance with the prescribed calculation formulas.

Implementation in our processes:

• From 01.03.2026, CBAM costs will be shown separately on our
order confirmations.

• Orders already in progress will be invoiced accordingly from 01.04.2026.

• CBAM costs will be shown transparently and separately on order confirmations and invoices.

This ensures a traceable, appropriate and legally compliant pass-through of the additional regulatory costs.