Dubrink updates

By Dubrink

Welcome to Dubrink updates. As the CBAM definitive phase shifts from legislative theory to operational reality, staying ahead of the regulatory curve is essential for maintaining market access. We handle the technical research so you can focus on your business, making the complex world of carbon policy easier to navigate.

China’s 15th five-year plan: decoupling and data friction

China’s strategic transition toward its 15th five-year plan (2026 to 2030) introduces a carbon dual control system, shifting from energy consumption intensity to absolute carbon emission quotas. While this move aligns with the EU’s focus on actual emissions, a significant verification gap persists. China’s recent air quality action plans prioritize local pollutants like pm2.5 but lack the integrated CO2 monitoring requirements essential for EU industrial site reporting.

For EU importers of Chinese steel and aluminum, this divergence creates a high-stakes compliance hurdle. Without integrated CO2 data at the source, auditors cannot confirm actual emissions, likely triggering a forced reliance on punitive EU default values. These default values include a 10% mark-up for 2026, significantly increasing the cost of entry for goods that cannot substantiate low-carbon claims through primary data.

The 31 March deadline: registry access and surveillance

With the application deadline for authorized CBAM declarant status approaching soon on the 31 march 2026, the compliance focus has shifted to registry execution. Importers who submit applications by this date may provisionally continue to import goods while the decision is pending; however, missing this window risks immediate legal blockages at the border.

National competent authorities are now utilizing the registry’s authorization management module to perform 50-tonne surveillance. To prevent split-consignment circumvention, authorities are exchanging data on importers reaching 90% of the 50-tonne annual mass-based threshold. Importers must ensure EURI numbers are correctly linked and data mapping is ready to meet high-volume reporting requirements and avoid validation errors.

Trans-atlantic divergence and WTO subsidy risks

Prospects for a US and EU carbon equivalence agreement continue to weaken as the us administration moves to expand fossil fuel infrastructure subsidies. Under the WTO agreement on subsidies and countervailing measures, these direct grants could be classified as actionable subsidies if they provide financial advantages to export-heavy sectors like chemicals.

Because the US lacks a federal, explicit carbon price, these multi-billion-dollar subsidies cannot be deducted from CBAM certificate liabilities. Under the regulation’s strict mechanics, importers can only claim a deduction if a verifiable carbon price has already been paid in the country of origin. Consequently, American industrial goods face the full financial impact of the EU border levy as the transition phase concludes this year.

Regional energy mix: Turkey’s solar expansion

Turkey is accelerating a 2gw solar expansion to capture the European market's demand for low-carbon electricity. However, under regulation (eu) 2023/956, electricity imports from third countries are subject to rigorous reporting. Unless turkish exporters provide verifiable primary data for specific installations meeting strict technical link criteria, the EU will apply default grid factors.

This reliance on default values could diminish the competitive advantage of these renewable projects. Importers must prioritize actual emissions data to reflect the lower carbon intensity of solar generation. Identifying these actual data sources remains the only viable path to cost mitigation as the benchmark for CBAM default values becomes increasingly aggressive.

Weekly executive takeaways

• Authorization deadline: importers must finalize authorized CBAM declarant applications by 31 march 2026 to avoid border blocks and shipment delays.

• Verification pressure: the divergence in China’s co2 monitoring increases the risk of reliance on default values with a 10% top-up; engaging accredited verifiers early is essential.

• Financial liability: the 2026 CBAM certificate price is based on the quarterly average of auction clearing prices, shifting to a more volatile weekly average in 2027.

• Data governance: the shift toward automated upload structures requires precise data mapping to avoid registry validation errors and ensure compliance.

The weekly EUA snapshot

The European union allowance (EUA) market remains the primary driver of the CBAM cost as it attempts to find a floor for the first compliance quarter.

Today's price: €66.31 (20 March 2026)

Key price pillars: sales of CBAM certificates are currently based on the quarterly average of auction clearing prices for 2026 imports.

The one-sentence bottom line: expect a range-bound week between €64 and €68 as the market reacts to mid-march compliance data and the first wave of definitive regime reporting.

Please be advised that all predicted values are an internal estimation based on the statements of globally trusted sources. Dubrink will not be held liable for mispredictions or unexpected shifts in the market.