If your company exports steel, cement, aluminum, fertilizers, hydrogen, or electricity to the European Union — directly or as an input within a product manufactured in Mexico — the CBAM applies to you. What was a voluntary report during the transition period until 2025 enters effective collection in 2026: carbon tariffs on the difference between your product's emissions and the European benchmark. For many Mexican tier-1 exporters, this means between 3% and 12% added on top of the sale price, which wipes out the margin without countermeasures.
This guide covers what the CBAM is in 2026, how the charge is calculated, which specific sectors fall within scope, and what Mexican exporters must do over the next 12 months.
What is the CBAM?
The Carbon Border Adjustment Mechanism is a European Union regulatory mechanism that applies a charge on the carbon embedded in imported products, equivalent to the price European industries would pay under the EU ETS (Emissions Trading System).
The logic: European companies pay for their emissions via the EU ETS. If Europe imported products without that charge, its own industries would be left at a competitive disadvantage. The CBAM "levels the playing field" by charging imports the equivalent cost.
Status 2026: the CBAM entered the effective collection period starting January 1, 2026. The 2023–2025 period was a transition with mandatory reporting only. Real charges are now in effect.
The 6 sectors in scope
The 2026 CBAM applies directly to these sectors when exporting to the EU:
- Steel (finished product and semi-finished) — the most impacted by export volume from Mexico
- Aluminum (ingot, profile, sheet)
- Cement (clinker, Portland cement, and variants)
- Fertilizers (ammonia, urea, nitrate)
- Hydrogen
- Electricity (imported directly into EU grids)
Important: the scope is expanding. The European Commission has already announced that for 2027–2028 it will add chemicals, polymers, and manufactured products that significantly incorporate steel/aluminum. If you export auto parts, appliances, architectural profiles, containers, or piping: it applies to you indirectly and probably directly within 2–3 years.
How the charge is calculated
The CBAM charge has 3 components:
1. Embedded emissions of the product
Measured in tons of CO₂ equivalent per ton of product (tCO₂e/t). Each product has a default value (the worst of the European benchmark) and a verified value (the real one, if your company demonstrates it with evidence).
- If you do not present evidence, the default value applies (always the highest)
- If you present validated evidence, the real value applies
Typical difference between default and real: 30–60% depending on the product. For many Mexican exporters, submitting a validated inventory cuts the CBAM charge to less than half.
2. CO₂ price in the EU ETS
The price benchmark is the weekly average of the EU ETS. In 2026 it ranges between €70 and €95 per ton of CO₂.
3. Discount for carbon paid at origin
If your company has already paid a carbon price in Mexico (via federal or state carbon taxes, or via a certified voluntary market), you can deduct it from the CBAM charge. Mexico has limited carbon taxes, but they exist and can be documented.
Simplified formula
CBAM charge = (Tons exported) × (tCO₂e/t of product) × (€/tCO₂ EU ETS) − Carbon paid in MX
Numerical examples
Example 1 · Structural steel exporter
- Volume exported to the EU: 12,000 ton/year
- Real emissions of its product: 1.8 tCO₂/t (verified)
- EU ETS price: €80/tCO₂
- Exchange rate: 22.5 MXN/EUR
Annual CBAM charge: 12,000 × 1.8 × €80 = €1,728,000 ≈ MX$38.9 million/year
Had it presented the default value (2.4 tCO₂/t instead of 1.8): the charge would be €2,304,000 ≈ MX$51.8 million. Difference from presenting validated evidence: MX$12.9 million/year.
Example 2 · Extruded aluminum exporter
- Volume exported: 3,500 ton/year
- Real emissions: 9.5 tCO₂/t (primary aluminum has a lot of embedded carbon)
- CBAM charge: 3,500 × 9.5 × €80 = €2,660,000 ≈ MX$59.8 million/year
If it uses recycled secondary aluminum (1.5 tCO₂/t): the charge drops to MX$9.4M. Difference from using recycled feedstock: MX$50.4 million/year.
Example 3 · Cement exporter
- Volume exported: 80,000 ton/year
- Real emissions: 0.85 tCO₂/t (low-carbon cement)
- CBAM charge: 80,000 × 0.85 × €80 = €5,440,000 ≈ MX$122 million/year
For carbon-intensive industries such as cement, the CBAM can represent 5–10% of the sale price. Without countermeasures, the margin evaporates.
What your company must do over the next 12 months
Step 1 · Verified product emissions inventory
Before any other action, you need to know precisely how many emissions each product you export to the EU embeds. This starts with properly classifying your emissions by Scope 1, 2, and 3 and requires:
- Consistent methodology (GHG Protocol Product Standard or equivalent)
- Primary data from your production process (not estimates)
- Validation by an external verifier certified by the EU
- Data traceability over 12 months
Typical cost of the verified inventory: MX$200,000 – MX$800,000 for a mid-sized company.
Step 2 · Registration as an operator in the CBAM portal
Starting January 2026, every exporter to the EU must register in the official CBAM portal managed by the European Commission. Registration is mandatory even if you export a single ton per year.
Step 3 · Quarterly report
Once registered, you must submit quarterly reports with:
- Volumes exported by category
- Embedded emissions (default or verified value)
- Supporting documentation
Step 4 · Annual payment of the CBAM charge
The charge is settled annually with CBAM certificates, which your company acquires through the portal at the EU ETS price.
Step 5 · Emissions reduction strategy
This is where the energy dimension becomes key. The main levers to reduce the emissions of the exported product:
- Migrate to Qualified User of the MEM and contract a package with CELs and/or certified renewable energy: significantly lowers Scope 2 (electricity). See qualified users complete guide.
- Direct renewable PPA (solar, wind): a deeper and more predictable reduction
- Efficient cogeneration with a lower emission factor than CFE Basic Supply
- Energy efficiency of the production process (reducing kWh per ton)
- CO₂ capture and reuse from the process (where technically feasible)
Each lever has a different CAPEX and horizon, but lowering emissions is directly proportional to lowering the CBAM charge. The investment pays off. To decide between investing in your own renewables or buying attributes, compare the ROI in own renewable portfolio vs. buying CELs.
Common mistakes in CBAM reporting
- Using the default value unnecessarily because the company did not want to invest in a verified inventory
- Reporting electricity consumption with the national emission factor when a contract with renewable energy already allows a lower factor
- Not including the discount for carbon paid at origin (if applicable, it must be documented)
- Lack of traceability in the primary process data
- Confusing location-based vs. market-based Scope 2 (the CBAM accepts market-based if there is a binding contract)
The Mexican exporters that will be most affected
Without being exhaustive, the Mexican industrial corridors most exposed to the 2026 CBAM:
- Steel: Monterrey, Coahuila, Michoacán
- Aluminum: Coahuila, Querétaro, Sonora
- Cement: Nuevo León, Hidalgo, Jalisco
- Fertilizers: Veracruz, Tamaulipas, Sinaloa
If your company is in any of these sectors and exports to the EU, the question is not whether the CBAM applies to you, but how much it costs not to have a strategy.
The connection with renewable energy
A significant fraction of the emissions of products such as steel and aluminum comes from the process's electricity consumption. If your electricity source moves from CFE Basic Supply (emission factor ~0.45 tCO₂/MWh) to a certified renewable PPA (factor 0.05 or less), the embedded emissions of your product drop substantially.
For a steelmaker exporting 12,000 ton/year (example 1 above): switching to 60% certified renewable electricity can lower the CBAM charge by MX$8–MX$15 million/year, which frequently pays back the PPA's CAPEX in less than 5 years from the CBAM side alone.
Do you need a CBAM strategy?
At Enerlogix we integrate the CBAM strategy within the Plan 360 Management and our sustainable services: we coordinate the emissions inventory, optimize Scope 2 via MEM/CELs/renewable PPAs, connect the data with your CBAM reports, and reduce the annual charge.
If your company exports to the EU in any of the 6 sectors in scope, request a free Plan 360 Management evaluation. Within 10 business days we deliver an estimate of the applicable CBAM charge, reduction levers, and ROI per lever.
To understand the full sustainability framework, read the pillar CELs, RECs and ESG in Mexico 2026.
Frequently asked questions
The CBAM (Carbon Border Adjustment Mechanism) is a European Union mechanism that applies a charge on the carbon embedded in imported products, equivalent to the price European industries pay under the EU ETS. It entered effective collection starting January 1, 2026; the 2023 to 2025 period was a transition with mandatory reporting only. For many Mexican tier-1 exporters it represents between 3% and 12% added on top of the sale price.
There are six when exporting to the EU: steel (the most impacted by volume from Mexico), aluminum, cement, fertilizers, hydrogen, and electricity imported directly into EU grids. The scope is expanding: the European Commission has already announced that for 2027 and 2028 it will add chemicals, polymers, and manufactured products that significantly incorporate steel or aluminum, such as auto parts, appliances, profiles, and piping.
With three components: the embedded emissions of the product in tons of CO2 equivalent per ton, the price of CO2 in the EU ETS (between 70 and 95 euros per ton in 2026), and the discount for carbon already paid in Mexico. The simplified formula is tons exported times emissions times EU ETS price, minus the carbon payment in Mexico. Without validated evidence the default value applies, always the highest.
Yes. The difference between the default value and the real verified value is usually 30 to 60% depending on the product, and for many exporters submitting a validated inventory cuts the charge to less than half. In the example of a steelmaker exporting 12,000 tons per year, presenting 1.8 instead of 2.4 tCO2 per ton saved 12.9 million MXN per year. The verified inventory costs between 200,000 and 800,000 MXN.
A significant fraction of the emissions of products such as steel and aluminum comes from electricity consumption. If your source moves from CFE Basic Supply (emission factor close to 0.45 tCO2 per MWh) to a certified renewable PPA (factor of 0.05 or less), the embedded emissions drop substantially. For the steelmaker in the example, switching to 60% certified renewable electricity can lower the charge by between 8 and 15 million MXN per year.
