Comply with the Carbon Border Adjustment Mechanism

To support its goal of reducing GHG emissions by 55% by 2030, the European Union has established a program that became operational on January 1, 2026: the Carbon Border Adjustment Mechanism (CBAM).

Photo of a road running through a forest, viewed from above, for the MACF header

Complying with the requirements of the
(CBAM)

The Carbon Border Adjustment Mechanism is based on a simple principle: applying the same carbon price to imported goods as to those produced within the EU that are subject to the carbon emissions trading system (EU ETS). Currently,six products or product categories are covered: steel, aluminum, cement, fertilizers, hydrogen, and electricity.

Under the MACF, importers of these goods must report the direct and indirect GHG emissions associated with them and pay the equivalent carbon content on these imports when they cross the European Union border at customs.

This policy addresses three main objectives:

Minimizing the Risk of Carbon Leakage
Preserving the Competitiveness of European Industries
Strengthenclimate action by encouraging non-EU countries to adopt more ambitious climate measures

Companies that fail to meet their obligations face the following consequences:

Financial:
A fine of €100 per missing tCO₂e (based on the number of certificates) between the reported figures and the actual emissions incorporated

>> Article 26 of Regulation 2023/956 (Article 16 of Directive 2003/87/EC)

Legal Information:
Revocation of CBAM/MACF authorization resulting in the blocking of imports at customs borders

>> Article 17-8 of Regulation 2023/956

Reputation:
Failure to comply leads to a loss of trust among partners and customers.

Our MACF Support

To address this complex issue, which requires expertise in energy, decarbonization, and responsible procurement, Maliro has developed a specialized solution consisting of six key steps:

1. Take the MACF training course at
. Understand the legal context, the company’s obligations, and the risks of penalties. Understand the definitions of key concepts: NC codes, scopes, imported goods, precursors, specific embedded emissions, direct emissions, indirect emissions, simple goods, complex goods, aggregated goods, differences from a product carbon footprint or a carbon footprint assessment, links to the European Union Emissions Trading System (EU ETS), etc.

2. Quantify risk exposure
To this end, we map risks by product type, supplier, and country.

3. Bringing Operations Under Control
We help our clients register on the 2.0 portal and ensure that declarations are submitted correctly. We work with them to define internal processes for CBAM/MACF compliance by coordinating the affected functions within the group: Procurement, Supply Chain, Compliance, and Sales. Finally, we monitor legislative developments.

4. Consider the downstream impacts of your value chain
Through the product portfolio, we assess the impact on customers and help convey the right pricing signal. We provide operational support to model the appropriate cost structure, which will be used in contract negotiations.

5. Engaging Suppliers
We train suppliers on regulations and their associated impacts, collect actual data from the value chain, and map the maturity level for each supplier. Learn more about our support for responsible procurement

6. Implement the right risk mitigation strategies
We support our clients in several ways:

by specifying the expected carbon content in the product specifications
by incorporating carbon footprint as a criterion in the selection of suppliers and during the contracting process
by adopting a collaborative approach with strategic suppliers to find joint solutions for reducing emissions from imported goods
and finally, by implementing a hedging strategy for CBAM/MACF certificates