The definitive CBAM regime began on 1 January 2026, following a transitional period in which importers reported embedded emissions without buying and surrendering certificates.
The initial product scope covers:
Importers bringing more than 50 tonnes of covered CBAM goods into the EU must apply for authorised declarant status. They then buy CBAM certificates linked to the emissions embedded in imported goods. The system is intended to reflect the carbon cost faced by comparable EU production, while allowing credit for an eligible carbon price already paid in the country of origin.
The European Commission published certificate prices of €75.36 per tonne of CO₂ for the first quarter of 2026 and €75.28 for the second quarter. Those prices do not by themselves determine an importer’s final liability: the amount also depends on verified emissions, product benchmarks, the applicable phase-in factor and any carbon price already paid abroad.
Steel and aluminium are directly covered, emissions-intensive products. Exporters therefore face two linked challenges: the potential cost of certificates and the administrative work needed to measure, verify and document embedded emissions. Where reliable data is unavailable, importers may have to rely on EU default values, which can increase uncertainty for producers and traders.
That makes CBAM particularly relevant to major exporters such as India, China and South Africa. A policy assessment cited in the supplied material estimates that CBAM could affect approximately $16 billion of developing-country exports annually, although that figure is not a country-specific estimate for those three economies.
The financial exposure is also designed to increase over time as free EU Emissions Trading System allowances are phased out. The World Bank describes the remaining free-allocation factor as 97.5% in 2026, 95% in 2027, 90% in 2028, 77.5% in 2029 and 51.5% in 2030. In practical terms, the share of the carbon cost reflected through CBAM rises as EU producers receive less free protection from the ETS price.
There is no single dependable 2030 revenue figure. Estimates vary according to assumptions about carbon prices, import volumes, emissions intensity, free-allocation phase-out and whether the EU expands the mechanism beyond its initial product scope.
Available estimates include approximately €1.5 billion annually from 2028, roughly €2.1 billion annually in another assessment, and a range of €5–9 billion for 2030 under the current scope. An earlier European Commission-related estimate cited by the Center for Global Development put potential 2030 revenue at €9.1 billion under a broader formulation.
The range matters. It shows why a precise headline number can be misleading, particularly while CBAM is still being phased in and its future coverage remains relevant to forecasts.
The BRICS complaint is not only that exporters may face an additional carbon-linked cost. It is also about the destination of the proceeds. European Parliament material says CBAM revenue is intended to accrue to the EU budget, while other analyses describe allocations connected to EU-level climate and budget priorities.
BRICS countries argue that money collected from developing-country exporters should instead help finance emissions reductions, industrial upgrading and climate adaptation in the countries affected by the measure. That demand is consistent with the ministers’ broader call for increased climate finance for developing countries.
This creates a direct political tension: the EU presents CBAM as a way to prevent carbon leakage and align the treatment of imports with domestic carbon costs, while BRICS sees the mechanism as a unilateral trade measure whose financial burden falls disproportionately on producers outside Europe.
Diplomatic condemnation is not the same as a WTO dispute. A formal case would normally begin with a member requesting consultations; if consultations failed, the complainant could seek a panel. The legal questions would include whether the mechanism discriminates against imported goods or foreign production methods, whether EU and imported products receive equivalent treatment, and whether the EU could justify the measure under the environmental exceptions in the General Agreement on Tariffs and Trade.
The EU’s defence is likely to focus on CBAM’s stated function as a counterpart to the domestic EU carbon price. The mechanism also allows recognition of an eligible carbon price paid in the country of production, arguments the EU can use to claim that it is addressing carbon leakage rather than imposing an arbitrary tariff. The central legal controversy is whether those design features are sufficient to overcome concerns about discrimination, reporting burdens and the treatment of foreign producers.
The available evidence indicates that South Africa has signalled interest in a complaint and that India, China and Brazil have raised legal or equity concerns. It does not establish that China has filed a CBAM-specific WTO dispute, nor does it establish a coordinated BRICS case.
The conflict could intensify as the payable share of embedded emissions grows and exporters gain more experience with the compliance system. EU trade agreements, negotiations and bilateral engagement may provide channels for consultation or technical adjustments, but they would not automatically prevent a WTO challenge.
The clearest conclusion is therefore narrower than claims of an imminent “CBAM trade war”: BRICS has created a strong political coalition against the EU’s approach, the economic pressure will rise as CBAM phases in, and formal litigation is plausible—but a unified BRICS WTO case and a completed Chinese challenge remain unverified in the available evidence.