CAKE at the ASEKOL Environmental Congress 2025
During the ASEKOL PL Environmental Congress in Pabianice, held on 4–5 September 2025, Jakub Boratyński, CAKE Expert, presented a presentation titled “Carbon footprint under scrutiny – CBAM as a challenge and an opportunity for business.” The presentation was devoted to the objectives and assumptions of the Carbon Border Adjustment Mechanism (CBAM).


The presentation covered current regulations and the resulting obligations for entrepreneurs, the simplifications introduced under the Omnibus package,
as well as the prospects related to the next stages of CBAM implementation. It also addressed preliminary estimates of the size and costs of so-called embedded emissions associated with
imports of products into Poland, both for the current list of regulated products and for a hypothetical scenario of its extension.
- The number of CBAM certificates that importers will be required to purchase in the target phase of the mechanism (from 2026 onwards) will not depend solely on the “content” of GHG emissions in imports (i.e. embedded emissions).
In the initial period, the obligation will cover only part of the embedded emissions, since in the coming years another policy aimed at protecting the competitiveness of EU industry will be in force – the allocation of free emission allowances. However, the scale of this allocation will gradually decrease, which means that the percentage of embedded emissions subject to CBAM will increase. - If producers in the country of origin of the import – similarly to those in the EU – bear the costs of GHG emissions (under an ETS system or in the form of a “carbon tax”), the number of required CBAM certificates will also be reduced (in the extreme case, if the country of origin applied a carbon price equal to that in the EU ETS, the CBAM obligation would not occur). This factor makes it difficult to forecast CBAM costs for importers, as it depends on the climate policies of third countries.
The detailed implementation of the general principles outlined above has not yet been agreed upon, and the specific formula for calculating the required number of CBAM certificates, along with other methodological solutions, is to be announced before the end of 2025.
Agenda:
Agenda ASEKOL PL (3.3 MiB, 85 hits)



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