The EU imposes CO₂ costs on imports produced in a manner harmful to the climate once they exceed a certain threshold. TÜV NORD advises integrating CBAM requirements into existing management systems.
With the start of the regulatory phase of the European Carbon Border Adjustment Mechanism (CBAM) on 1 January 2026, the EU will impose carbon costs on imports produced in a way that is harmful to the climate. The aim is to prevent European companies from facing competitive disadvantages. This means that small and medium-sized enterprises (SMEs) in particular are facing a new regulatory reality. Whilst companies importing fewer than 50 tonnes of CBAM-relevant goods into the EU per year are exempt from purchasing CO₂ allowances, they must be able to provide verifiable evidence of their exemption. TÜV NORD advises making use of existing management systems for this purpose.
SMEs, too, must systematically record and analyse their import flows. The assumption that companies below the threshold are ‘automatically exempt’ is incorrect. “Exemption from CBAM is subject to a clear obligation to provide evidence. Anyone who, during an audit, cannot prove that they remain below 50 tonnes risks being retrospectively classified as fully subject to the scheme,” says Olgun Özyurt, Head of CBAM at TÜV NORD. Of particular importance here is the correct identification of the relevant goods using customs tariff codes, as well as the annual aggregation of imported volumes across all affected product groups.
The necessary evidence is less complex than many companies initially assume. Whilst large importers must calculate detailed CO₂ emissions and purchase the corresponding certificates, the requirement for SMEs focuses primarily on proper documentation. “It is not about carbon accounting in the strict sense, but about transparency in one’s own import data,” explains Özyurt. “Invoices, customs documents and internal records are usually sufficient – provided they are complete, consistent and available at the right time.”
Utilising existing management systems
TÜV NORD considers the integration of these requirements into existing management systems to be a particularly efficient approach. “CBAM is not an isolated issue, but fits very well structurally into established processes, particularly in quality and environmental management,” emphasises Özyurt. For example, the requirements can be integrated directly into an existing ISO 9001 system, for instance by extending procurement and import processes to include a CBAM relevance check or by utilising existing documentation structures. Internal audits can also be easily supplemented with corresponding checkpoints.
An environmental management system in accordance with ISO 14001 also offers clear points of integration. Here, CBAM can be classified as a regulatory environmental requirement and integrated into existing mechanisms for assessing environmental aspects and compliance obligations. “Companies that already work with environmental aspects and supplier data in a structured manner have a clear advantage,” explains Özyurt. “They have the organisational foundations in place to implement new regulatory requirements such as CBAM quickly and efficiently.”
A key factor for success here is the ongoing monitoring of import volumes. As the volume threshold applies both annually and cumulatively across all affected goods, TÜV NORD recommends continuous monitoring. “An additional order or a change to the supply chain can quickly lead to the threshold being exceeded, with the result that the company must register as a CBAM declarant,” warns Özyurt.
CBAM has an indirect impact on companies not formally affected
Furthermore, CBAM is also making itself felt for companies along the supply chain that are not formally affected. Rising costs, new data provision requirements and changing competitive conditions mean that SMEs, too, are increasingly having to grapple with the issue. “CBAM has an indirect impact on almost all companies involved in international supply chains,” says Özyurt. “Those who establish transparency at an early stage and structure their processes will gain a clear competitive advantage.
Against the backdrop of plans to extend CBAM to further product groups in the coming years, TÜV NORD recommends viewing the current requirements not merely as an obligation, but as a strategic opportunity. “The current phase is ideal for establishing structures and gaining experience,” emphasises Özyurt. “CBAM is here to stay and will continue to evolve, and companies that integrate their reporting obligations into existing management systems at an early stage will have a clear long-term advantage.”
About the expert:
Dr Olgun Özyurt is Head of CBAM at TÜV NORD CERT. As a TIC manager, he is responsible for the Carbon Border Adjustment Mechanism (CBAM) division. He is an appointed EU ETS auditor and leads the innovation project to develop the CBAM verification application.
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