Dubrink compliance updates: Your Practical Update on CBAM, PPWR & EUDR

Regulation recap

CBAM:

• A system that balances carbon costs between goods made inside Europe and those imported from abroad. When businesses bring in energy-intensive materials like steel, aluminium, cement, fertilisers, hydrogen, or electricity, they report the embedded carbon emissions and buy CBAM certificates matching EU carbon market prices.

PPWR:

• One set of packaging rules replacing the different national laws across the EU. It focuses on cutting waste across the board by banning unnecessary single-use plastic formats, putting a cap on empty box space, restricting chemicals like PFAS in food packaging, and making sure all packaging is recyclable.

EUDR:

• A traceability rule ensuring goods sold in Europe do not come from recently cleared forests. For products like coffee, cocoa, beef, palm oil, rubber, soy, and timber, companies must trace shipments back to the exact farm plot with precise GPS coordinates to show the land was not deforested after 2020.

Updates:

1. CBAM: Fresh certificate prices and the push for verified data

Both Brussels and London have rolled out important updates for the Carbon Border Adjustment Mechanism. The transition period is wrapped up, and actual carbon accounting is taking center stage.

• EU Q3 2026 certificate price published: The European Commission set the official Q3 2026 CBAM certificate price at €82.32 per ton of CO2e, marking a noticeable step up from €75.28 in Q2 2026.

• 2026 Import year baseline: Under Implementing Regulation (EU) 2025/2547, the reporting period for goods imported in 2026 is officially set to the 2026 calendar year. For this period importers will have to submit their CBAM declaration and surrender the required certificates by September 30, 2027. For the following reporting period of 2027, deadlines turn quarterly with the importer required to hold 50% of their required certificates (Based on default values) for each given quarter. The final declaration and surrender of certificates will continue to follow the 2026 trend. 

• UK CBAM default values and rates: HMRC released official UK CBAM default emission values and draft force-of-law notices ahead of the UK launch on 1 January 2027. UK rates will be calculated each quarter based on the UK Emissions Trading Scheme (ETS) auction price.

• Carbon Price Relief (CPR) rules: Importers into the UK can claim relief if their goods paid an overseas carbon price (such as the EU ETS). To claim this relief, suppliers must provide an official verification form signed by an independent accredited verifier. Although there were talks on furthering this Idea through a linkage of the EU and UK CBAM systems, there is no clear information on this and importers are urged to plan based on the current system limitations.

• Accredited verifiers roll out: The first Verifying companies are now accredited for EU CBAM. You can contact us if you would like to find out about who can verify your suppliers - or if you are a supplier yourself we can connect you with companies to verify your installation. Importers should actively urge their overseas manufacturers to engage an accredited verifier now to avoid scrambling before 2027 filing deadlines.

2. PPWR: Harmonized rules and role clarifications

The EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) entered general application on 12 August 2026, harmonizing packaging laws across all EU Member States.

• Direct application across Europe: The old Packaging Directive is gone. One single rulebook now applies across the Netherlands, Germany, Belgium, and beyond.

• Facts decide your role: Under PPWR, your legal obligations depend on your actual operational role (Manufacturer, Importer, Distributor, or EPR Producer). Importers bringing goods from outside the EU and manufacturers placing packaged items on the EU market carry the legal burden for declarations of conformity and technical files. Get in touch with us today if you need help defining your role and understanding your obligations.

• Pallet wrappings and straps relief: Under Delegated Decision (EU) 2026/429, economic operators using pallet wrappings and straps for pallet stabilization during transport are exempt from the strict 100% reuse requirement, saving businesses substantial packaging-line retooling costs.

• Stock exhaustion protection: Packaging manufactured and put into stock before 12 August 2026 does not need to be pulled off shelves or scrapped; it can remain in circulation while new compliant packaging phases in.

3. EUDR: Timeline set and core text kept intact

The EU Deforestation Regulation (EUDR) is heading toward its critical compliance milestone following amendments to the rollout schedule.

• Firm application dates: Following the postponement under Regulation (EU) 2025/2650, the EUDR applies from 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small enterprises.

• No major reopening of core law: The European Commission has affirmed that the core text of the regulation will not undergo major rewrites. Due diligence obligations remain anchored in supply chain traceability back to the plot level.

• Downstream clarity: Due diligence responsibilities rest on the first operator placing relevant goods on the EU market, while downstream operators and traders must collect, retain, and pass on the reference numbers for five years.

Did you know?

• Beer bottle caps are officially independent: Under PPWR rules, metal crown corks on glass bottles are counted as separate packaging components because you must remove them completely before drinking!

• Returning goods still need a CBAM shoutout: Even if an imported shipment qualifies for customs return relief where the embedded emissions figure is logged as zero, it must still be reported in your annual CBAM declaration.

• GPS coordinates down to the size of a coffee mug: Under EUDR rules, whenever you import commodities like coffee, cocoa, or cattle, you have to submit the exact GPS coordinates of the specific farm plot using at least six decimal places. In geography terms, six decimal places pinpoints a location down to roughly 10 to 11 centimeters (about 4 inches). That means the EU’s IT system technically requires precision sharp enough to target an individual branch on a cocoa tree or a cow’s favorite grazing spot! 

Key takeaways: What to do this month

1. Kick off supplier audits early: Do not wait for 2027. Check whether your overseas suppliers have their monitoring plans in place and connect them with one of the newly accredited CBAM verification bodies.

2. Review your packaging dossiers: Check your supply chain to confirm who qualifies as the manufacturer or EPR producer under PPWR, and ensure your packaging technical documentation matches EU conformity rules.

3. Map your supply chains for deforestation: If you handle EUDR-covered commodities, start securing plot-level geolocation coordinates and producer reference data well before the December 2026 deadline.

4. Centralize your data with Dubrink: Tracking CBAM emissions, PPWR dossiers, and EUDR traceability across spreadsheets creates costly risks. Dubrink combines automated reporting, supplier engagement, and audit-ready data tracking into one unified platform so your business stays ahead of Europe's evolving trade landscape.