A leading environmental consultancy is urging mining and metals exporters in the United States to prepare for new EU emissions laws to avoid extensive penalties.
With less than a year before the stringent new rules are fully implemented, Tunley Environmental is urging exporters to the EU to prepare now so that they are in full compliance by January 1, 2026.
“It is complex,” said Tunley biodiversity scientist Dr. Alejandra Zazueta Lopez. “We have seen a surge in interest from American companies wanting to understand what information they are required to provide, the calculations they need to make, and to how to report.
“We are recommending that those companies likely to be impacted start right away to take the necessary steps to come into full compliance by the first of January next year.”
The EU’s landmark Carbon Border Adjustment Mechanism (CBAM) is designed to put a carbon price on certain imported goods.
It will ensure that producers outside the European Union face similar costs as EU-based manufacturers, who participate in the EU Emissions Trading System (EU ETS).
Initially, CBAM will target six carbon-intensive industries:
- Iron and steel, where 30% of EU demand is met by foreign supply
- Cement, which produces significant direct and indirect emissions
- Fertilizers, which generate both direct and indirect emissions
- Aluminum production, which requires extensive energy input
- Hydrogen manufacturing processes
- Electricity generation and distribution.
Companies in these sectors will need to report embedded emissions generated during the production process, and to purchase certificates equivalent to the carbon price paid by EU manufacturers under ETS.
Reporting will require intimate knowledge of complex and often global supply chains where raw materials and basic products pass through multiple manufacturers before reaching the final customer.
Companies that fail to comply with CBAM’s reporting requirements for imported goods will face severe penalties linked to the ETS carbon price, currently around €85 euros per ton of CO2e. Carbon pricing will be gradually increased and free allowances phased out between 2030 and 2035.
“Companies should start as soon as possible to gather all the emissions information for both them and their suppliers,” said Dr. Zazueta Lopez. “We are helping companies in many ways, such as clarifying what – and how – they need to report, detailing the information they need from their suppliers, reviewing and ensuring the calculations they make are correct, and providing specific CBAM training for them and their suppliers.
“We are seeing a significant surge of interest in all these aspects of our CBAM consulting services, which are designed to help businesses navigate these challenges and ensure smooth compliance and cost efficiency.”
It is expected that the EU will broaden the scope of CBAM by 2030 to include other ETS sectors, such as aviation and maritime transportation.
The UK has also announced plans for its own CBAM policy starting in 2027 and mirroring the EU approach by covering the same iron and steel, aluminum, cement, fertilizer, and hydrogen sectors, but not electricity.
About Tunley Environmental
Tunley Environmental comprises a large team of PhD-level scientists with extensive knowledge and expertise in environmental sciences. This comprehensive understanding allows the company to provide innovative and scientific solutions at the highest level to clients. Headquartered in the UK with significant global projects, its science-based approach and commercial aptitude ensures it can identify realistic opportunities to reduce the negative impact organizations and products have on the environment.

