CBAM is now paying: what the EU carbon levy means for Brazil's steel and fertiliser

The EU's Carbon Border Adjustment Mechanism (CBAM) entered its definitive, paying phase on 1 January 2026. It puts a carbon price on the embedded emissions of goods imported into the EU across six sectors — cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Brazil's exposure is narrow but real: it sits almost entirely in steel and nitrogen fertilisers, together worth somewhere around €1–2 billion a year in exports to the EU. The first quarterly certificate price, published in April, came in at roughly €75 per tonne of CO2, tracking the EU's own carbon market.

The legal obligation does not fall on you. Under CBAM the party that registers, buys certificates and surrenders them is the EU importer — the authorised declarant — not the Brazilian producer. No mill in Minas Gerais has to file anything in Brussels. The catch is how the importer is charged: on the emissions embedded in your goods, and if you do not hand over verified figures, on EU default values set deliberately high to reward those who do. So the cost reaches you indirectly but unmistakably, through a buyer who now pays more for your tonne than for a cleaner-documented competitor's. A mass-based exemption removes importers under 50 tonnes a year, which covers samples and trial shipments but not commercial volume — if you fill containers, assume you are in scope.

That makes this a data exercise, not a customs one, and the work runs ahead of the bill. EU importers do not buy their first certificates until February 2027, for emissions embedded in 2026 goods, with surrender due by September that year. But the figures they will be priced on are being generated now, across this year's shipments. The durable response for an exporter is to commission third-party verification of actual emissions for the relevant product lines and share it with EU buyers in a form they can lodge — before the default values do the talking for you.

There is a longer-term offset worth tracking. Article 9 of the regulation lets an importer deduct a carbon price already paid in the country of origin, euro for euro. Brazil established its own emissions trading system, the SBCE, under federal law in December 2024, but it remains in build-out — cap levels, allocation and registry are still being finalised — and the Commission has not yet recognised it for Article 9 purposes. Practically, that means no deduction today and most likely none before 2027 or 2028. It is a reason to document any domestic carbon cost carefully now, not a discount you can bank this year.

If your route runs Brazil → EU in steel or fertiliser, the scan flags whether CBAM sits on your critical path, what verified-emissions data your buyers will expect, and how the cost compares against the cleaner origins they could switch to.