INTRODUCTION
The EU’s Carbon Border Adjustment Mechanism entered its definitive full compliance phase on 1 January 2026, becoming the first fully operational border carbon adjustment to charge costs based on the emissions intensity of imported goods—the first time a carbon price in a given jurisdiction has been externalized beyond its borders.1 CBAM is designed to put a fair price on carbon emitted during the production of carbon-intensive goods entering the EU and to encourage cleaner industrial production in non-EU countries.2 For developing and transitional economies, the CBAM presents a complex duality: while the EU’s commitment to decarbonization is admirable, the mechanism risks imposing disproportionate costs on nations with close trade ties to the EU and limited fiscal capacity to decarbonize.3 At the same time, the CBAM is triggering a global cascade of domestic carbon pricing and green tax reform, as governments recognize that pricing carbon domestically retains revenues that would otherwise flow to European coffers.
This article examines the CBAM’s operational architecture, its trade and competitiveness impacts, its role as a catalyst for domestic carbon pricing and green tax reform, and the equity concerns it raises, before offering actionable policy recommendations for the EU, developing countries, and international institutions. The methodology combines documentary analysis of EU regulatory texts and institutional reports with trade impact data from the World Bank CBAM Exposure Index, UNCTAD CGE modelling, and AFD multi-regional input-output analysis, supplemented by comparative case studies selected using the ‘most different systems’ design.4
MATERIALS AND METHODS
This study employs a qualitative policy-analysis methodology combining documentary review, comparative policy assessment, and case study analysis. Primary sources include EU Regulation 2023/956 and its implementing acts, together with reports from the World Bank, UNCTAD, OECD, IMF, ICAP, IEEP, IISD, and the Belfer Center at Harvard Kennedy School. Trade impact data are drawn from the World Bank CBAM Exposure Index, UNCTAD’s Computable General Equilibrium (CGE) modelling, and the Agence Française de Développement’s Multi-Regional Input-Output analysis. Six country and regional cases—Turkey, India, Brazil, Mozambique, Ukraine, and the South Caucasus—were selected via the ‘most different systems’ design5 to illustrate variation across dimensions of CBAM exposure, institutional capacity, and policy response. The temporal scope extends from the CBAM’s legislative proposal in July 2021 through its definitive implementation in January 2026 and the subsequent early compliance period.
The theoretical rationale for border carbon adjustments rests on the concept of carbon leakage—the relocation of carbon-intensive production to jurisdictions with weaker regulations—which the OECD estimates can offset domestic emissions reductions by approximately 13% in carbon-intensive sectors.6 From a trade theory perspective, BCAs are criticized as potentially incompatible with WTO rules and as a form of green protectionism.7 From a climate justice perspective, even modest trade impacts can generate severe socioeconomic consequences in low-income economies where affected sectors are critical sources of employment.8 The UN Secretary-General has highlighted how industrial policies in developed nations perpetuate a growing productive capacity divide, and without affordable technology transfer, developing countries risk marginalization in the low-carbon transition.9
The global carbon pricing landscape provides the broader analytical backdrop. There are now 80 carbon pricing instruments in operation worldwide, covering approximately 28% of global emissions and mobilizing over USD 100 billion in public revenues in 2024.10 11 However, the global average carbon price remains around USD 19 per ton,12 far below EU ETS allowance prices of €74–100 per ton,13 and well below the USD 40–80 range recommended by the High-Level Commission on Carbon Prices.14 This price differential is precisely what gives the CBAM its trade-altering potential and its fiscal incentive for domestic carbon pricing adoption.
DATA ANALYSIS
The CBAM was introduced as part of the EU’s Fit for 55 package and initially covers cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen—the most carbon-intensive sectors at highest risk of carbon leakage.15 In 2022, iron and steel represented 55% of CBAM-covered goods by value, with electricity and aluminium each comprising 19%.16 Under the definitive compliance regime, importers must register as authorised declarants, have embedded emissions verified by accredited third parties, and purchase and surrender CBAM certificates annually at prices linked to EU ETS allowance prices, adjusted for any carbon price already paid outside the EU.17 By 7 January 2026, more than 12,000 economic operators had submitted applications for authorised declarant status, with 10,483 import declarations validated automatically in the first week alone.18 In October 2025, the EU adopted a mass-based threshold under its Omnibus simplification package, exempting importers of 50 tons or less per year—covering approximately 90% of importers.19 20 The scope is designed to expand through further legislation in early 2026 to capture more than 50% of ETS-covered sector emissions by 2034.21
Table 1: CBAM Compliance Cycle for Importers and Non-EU Producers
| Step | Actor | Action | Key Requirement |
|---|---|---|---|
| 1 | EU Importer | Register as Authorised CBAM Declarant | Annual registration in CBAM Registry |
| 2 | Non-EU Producer | Report embedded emissions in goods | Facility-level emissions data required |
| 3 | Accredited Verifier | Third-party verification of embedded emissions | Accreditation by national authority |
| 4 | EU Importer | Purchase CBAM certificates | Price linked weekly to EU ETS allowances |
| 5 | EU Importer | Deduct any carbon price paid abroad | Must be documented and verified |
| 6 | EU Importer | Surrender CBAM certificates annually | Quantity = verified embedded emissions − deductions |
Source: Authors’ compilation based on Regulation (EU) 2023/956 and European Commission CBAM guidance.
The trade impacts of the CBAM on developing countries are significant and unevenly distributed. UNCTAD estimated that developing country exports in targeted sectors would fall by 1.4% at a CBAM price of USD 44 per ton of CO₂, and by 2.4% at USD 88 per ton, with developing countries losing USD 10.2 billion in income and a net global income loss of USD 8.3 billion.22 23 These figures likely understate the actual impact, as EU ETS prices at CBAM’s introduction materially exceed the levels assumed in UNCTAD’s analysis.24 The World Bank finds that Mozambique faces the highest relative CBAM exposure at 0.6% of GDP, followed by Ukraine at 0.5% and Egypt at 0.2%.25 Mozambique is by far the most affected in relative terms, with almost 20% of total exports consisting of CBAM-covered products, predominantly aluminium from a single smelter (Mozal).26 Beyond direct trade impacts, the CBAM generates cascading supply chain effects as EU importers push compliance costs downstream to SMEs that lack data management or decarbonization capacity.27 A CBAM priced at USD 44 per ton would reduce carbon leakage from 13.3% to 5.2%, yet its direct contribution to cutting global CO₂ is estimated at only 0.1%,28 raising a fundamental question about whether the CBAM functions primarily as a climate instrument or as a competitiveness protection mechanism.
The CBAM’s most significant global implication may be its catalytic effect on domestic carbon pricing and green tax reform. Countries can introduce national carbon pricing mechanisms to ensure revenues stay with the exporting country rather than flowing to the EU.29 The Belfer Center has described this as a ‘virtuous cycle’: domestic carbon pricing reduces CBAM liability while generating domestic fiscal revenues and incentivizing emissions reductions.30 Equally important, the CBAM creates strong downstream incentives for countries to adopt green tax incentives for renewable energy and low-carbon industrial investment, since lower production emissions directly reduce future CBAM exposure. Countries that combine domestic carbon pricing with incentives for clean technology adoption can simultaneously retain CBAM revenues and build longer-term export competitiveness in an increasingly carbon-constrained global market.31
The cascade of policy responses has been remarkable in scope and speed: Turkey is launching a national ETS pilot aligned with EU rules; Brazil passed key regulated carbon market legislation in May 2025, with implementing decrees adopted in October 2025 (Decree 12,677); Indonesia is preparing a national ETS and has launched a voluntary carbon exchange; Japan is developing its GX-ETS voluntary trading scheme; Morocco is planning a carbon tax road map; South Korea has established a dedicated CBAM task force in technical discussions with the EU; and Israel plans an excise-based carbon price on fuels.32 The UK and Norway are each preparing their own border carbon adjustment mechanisms from 2027, while the US, Canada, and Australia are at early development stages.33 The IISD warns, however, that a proliferation of differing CBAM regimes risks excluding developing country exporters that cannot bear the cost of complying with multiple MRV frameworks.34
CASE STUDIES: DIVERSE NATIONAL RESPONSES
Turkey represents the most CBAM-exposed middle-income economy, given its deep EU trade integration in steel and aluminium. Its response has been notably proactive: launching a national ETS pilot aligned with EU rules reflects a strategic calculation that domestic carbon pricing—even if politically challenging—is preferable to ceding carbon revenues to the EU.35
India contests the CBAM on grounds of common but differentiated responsibilities and WTO compatibility,36 while simultaneously developing its own carbon market infrastructure. This duality of political resistance and pragmatic adaptation is driven by the significant CBAM exposure of India’s steel and aluminium sectors.
Brazil benefits from a relatively clean electricity grid powered predominantly by hydropower, making its industrial production less carbon-intensive than many competitors. Research demonstrates that while Russia, India, Africa, and China face trade balance deterioration after CBAM implementation, Brazil’s position improves.37 Brazil’s passage of regulated carbon market legislation in May 2025, with implementing decrees adopted in October 2025, positions it to leverage the CBAM as a long-term competitive advantage.
Mozambique represents the extreme case of developing-country vulnerability: almost 20% of total exports are CBAM-covered, concentrated in a single aluminium smelter (Mozal), combined with limited fiscal capacity, weak MRV infrastructure, and constrained access to green financing.38 This case powerfully illustrates why the CBAM cannot be assessed in isolation from broader questions of climate finance and development equity.
Ukraine faces a particularly challenging convergence of second-highest CBAM exposure in GDP terms, ongoing conflict-related economic disruption, and EU accession aspirations that simultaneously motivate and complicate carbon pricing alignment. Potential CBAM-related investment losses in 2026–2030 could reach USD 2.7 billion,39 and Ukraine is preparing an appeal to the EU for postponement of its CBAM obligations.
The South Caucasus region, including Georgia and Azerbaijan, represents an important and underexamined frontier for CBAM-driven carbon pricing reform. Georgia appears among the countries most exposed by the World Bank’s relative CBAM exposure index,40 while Azerbaijan—a major hydrocarbon exporter that hosted COP29 in Baku in November 2024—faces growing pressure to implement domestic carbon pricing both from CBAM and from its own Paris Agreement commitments to reduce emissions by 35% by 2030. Both countries exhibit significant carbon-intensive industrial activity alongside limited carbon pricing infrastructure, and both are increasingly engaged with World Bank and IOTA-led technical assistance programs for carbon market readiness. The South Caucasus therefore offers a compelling case study of how CBAM, combined with post-COP political momentum, can accelerate green fiscal reform in resource-dependent transitional economies.
EQUITY CONCERNS AND THE CLIMATE JUSTICE DIMENSION
The CBAM has become a focal point for North–South tensions in climate governance. Developing countries view it as an external imposition that risks exacerbating trade tensions and undermining international climate agreements.41 The mechanism has been widely perceived as protectionist by the African negotiating group and BRICS nations. Escalating these geopolitical tensions, Russia filed a formal WTO complaint against the mechanism on 12 May 2025 (case DS639).42 A fundamental equity concern is the capacity gap: the EU’s own ETS developed over two decades with substantial institutional support and progressive regulatory refinement, yet developing country producers are expected to achieve comparable MRV capacity within a compressed timeframe.43 The switch to cleaner production processes will be particularly hard for the least developed countries, which lack both the financial resources and access to clean technologies required.44
While a European Parliament resolution calls for special treatment of LDCs and Small Island Developing States, current CBAM regulation provides no formal exemptions for any developing country.45 The EU has proposed a €200 billion Global Europe instrument for 2028–2034 with a 30% climate and environment spending target,46 and UNCTAD has called for a portion of CBAM revenues to be directed toward accelerating cleaner production in developing countries.47 Both commitments remain insufficiently operationalized and disconnected from a clear, accessible disbursement mechanism for the most affected economies.
CONCLUSION
The EU CBAM represents a paradigm shift in global climate governance, fundamentally reconfiguring the relationship between carbon pricing, international trade, and national fiscal policy. This study has demonstrated that its impacts on developing and transitional economies are significant, multidimensional, and unevenly distributed. The concentration of effects in specific sectors and communities generates disproportionate consequences in economies characterized by limited export diversification, weak institutional capacity, and constrained fiscal resources.
At the same time, the CBAM’s catalytic effect on domestic carbon pricing and green tax reform may ultimately prove its most consequential global contribution—even as its direct environmental impact remains limited at an estimated 0.1% reduction in global CO₂.48 The fiscal sovereignty logic is compelling: countries that price carbon domestically retain revenues that would otherwise accrue to the EU, while simultaneously building the green tax incentive frameworks needed to drive renewable energy investment and industrial decarbonization. The South Caucasus, including Azerbaijan and Georgia, illustrates how this dynamic is reshaping fiscal policy in resource-dependent economies beyond the article’s primary case studies.
Resolving the central tension between the CBAM’s legitimate anti-leakage objective and its potential to deepen trade inequalities requires moving beyond unilateral design to genuine multilateral engagement: meaningful revenue recycling for affected developing countries, accessible MRV technical assistance, and transparent procedures for recognizing diverse domestic carbon pricing approaches. Whether the CBAM becomes a catalyst for inclusive green transition or a source of deepened climate-trade tensions will depend on the equity-oriented choices made by the EU, developing economies, and international institutions in the years immediately ahead.
RECOMMENDATIONS
Drawing on the preceding analysis, the following policy recommendations are offered for multiple stakeholder groups.
For the European Union:
• Establish a dedicated CBAM revenue recycling fund directly linked to CBAM revenues and targeted at decarbonization support in the most affected developing economies, addressing climate justice concerns and strengthening WTO defensibility.
• Significantly expand MRV technical assistance programs, prioritizing Mozambique, Ukraine, Georgia, Zimbabwe, and India as the most exposed economies by World Bank exposure index.
• Streamline carbon price recognition procedures for third-country systems through genuine dialogue with affected countries, and expedite the development of transparent default carbon price values by country.
For Developing and Transitional Economies:
• Implement domestic carbon pricing starting with modest rates and clear escalation pathways to retain fiscal sovereignty, recycling revenues to support affected industries, protect vulnerable households, and finance renewable energy investment.
• Pair carbon pricing with green tax incentives for renewable energy adoption and clean technology investment—lower production emissions directly reduce future CBAM exposure and build long-term export competitiveness.
• Invest in facility-level emissions measurement and reporting infrastructure to minimize reliance on default CBAM values, which carry escalating surcharges rising 10% in 2026, 20% in 2027, and 30% from 2028 onwards.
• Establish dedicated inter-ministerial working groups to assess CBAM sector exposure, develop decarbonization roadmaps, and coordinate collectively with other affected countries to strengthen multilateral negotiating positions.
For International Institutions:
• The WTO, UNFCCC, World Bank, and OECD should develop common standards for carbon pricing recognition, MRV protocols, and emissions measurement to reduce compliance costs and promote interoperability between national and regional carbon pricing systems.
• Commission regular, independent impact assessments of the CBAM’s actual—not merely modelled—effects on developing countries as implementation data becomes available, to inform adaptive and equity-oriented policy reforms.
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Footnotes
1. Zero Carbon Analytics, Carbon Border Adjustment Mechanisms Require Coordinated Global Action (2025), https://zerocarbon-analytics.org/finance/carbon-border-adjustment-mechanisms-require-coordinated-global-action/.
2. European Commission, Carbon Border Adjustment Mechanism, DG TAXUD (2023), https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en.
3. Foundation for European Progressive Studies (FEPS), Evaluating the Impact of CBAM on Developing Countries (2025), https://feps-europe.eu/publication/evaluating-the-impact-of-cbam-on-developing-countries/.
4. Adam Przeworski & Henry Teune, The Logic of Comparative Social Inquiry (Wiley 1970).
5. Adam Przeworski & Henry Teune, The Logic of Comparative Social Inquiry (Wiley 1970).
6. Center for American Progress, Designing a New Paradigm in Global Trade (2024), https://www.americanprogress.org/ (accessed 28 February 2026).
7. World Bank, State and Trends of Carbon Pricing 2025 (2025), https://www.worldbank.org/en/publication/state-and-trends-of-carbon-pricing (accessed 28 February 2026).
8. Carnegie Endowment for International Peace, A Political Economy Perspective on the EU’s Carbon Border Tax (2023), https://carnegieendowment.org/research/2023/05/a-political-economy-perspective-on-the-eus-carbon-border-tax (accessed 28 February 2026).
9. Center for American Progress, Designing a New Paradigm in Global Trade (2024), https://www.americanprogress.org/ (accessed 28 February 2026).
10. World Bank, State and Trends of Carbon Pricing 2025 (2025), https://www.worldbank.org/en/publication/state-and-trends-of-carbon-pricing (accessed 28 February 2026).
11. World Bank, Carbon Pricing Revenues Exceeded $100 Billion in 2024, Press Release (10 June 2025), https://www.worldbank.org/en/news/press-release/2025/06/10/global-carbon-pricing-mobilizes-over-100-billion-for-public-budgets (accessed 28 February 2026).
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20. International Carbon Action Partnership (ICAP), EU Adopts Simplifications of CBAM Rules Ahead of the Compliance Phase Starting in 2026 (2025), https://icapcarbonaction.com/en/ (accessed 28 February 2026).
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22. International Institute for Sustainable Development (IISD), The Use of Green Tax Incentives for Renewable Energy Deployment in Emerging and Developing Countries (Kabir Mataba, 2025), https://www.iisd.org/publications/report/green-tax-incentives-renewable-energy (accessed 28 February 2026).
23. UNCTAD, A European Union Carbon Border Adjustment Mechanism: Implications for Developing Countries, UNCTAD/OSG/INF/2021/2 (2021), https://unctad.org/publication/european-union-carbon-border-adjustment-mechanism-implications-developing-countries (accessed 28 February 2026).
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29. GMK Center, How Countries Around the World Are Responding to the EU CBAM (June 2025), https://gmk.center/en/infographic/how-countries-around-the-world-are-responding-to-the-eu-cbam-june-2025/ (accessed 28 February 2026).
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32. GMK Center, How Countries Around the World Are Responding to the EU CBAM (June 2025), https://gmk.center/en/infographic/how-countries-around-the-world-are-responding-to-the-eu-cbam-june-2025/ (accessed 28 February 2026).
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40. International Institute for Sustainable Development (IISD), The Use of Green Tax Incentives for Renewable Energy Deployment in Emerging and Developing Countries (Kabir Mataba, 2025), https://www.iisd.org/publications/report/green-tax-incentives-renewable-energy (accessed 28 February 2026).
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