What are the phases of CBAM implementation?

The Carbon Border Adjustment Mechanism (CBAM) is being implemented in two phases: a transitional phase and a permanent phase.The CBAM transitional phase runs from October 1, 2023 to December 31, 2025 and requires EU importers to report the embedded greenhouse gas emissions of in-scope goods on a quarterly basis, without purchasing CBAM certificates.The CBAM permanent phase begins on January 1, 2026. From this point forward, importers must submit annual emissions declarations and purchase CBAM certificates to cover a growing share of embedded emissions, with full financial coverage required by 2034.

What is the Carbon Border Adjustment Mechanism (CBAM)?

The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation that places a carbon price on certain imported goods based on their embedded emissions.CBAM is designed to prevent carbon leakage by ensuring imported products face a comparable carbon cost to goods produced within the EU under the EU Emissions Trading System (EU ETS). The regulation currently applies to carbon-intensive goods such as iron and steel, aluminum, cement, fertilizers, electricity, and hydrogen, and requires importers to calculate and report emissions using defined EU methodologies.

What is a CBAM certificate?

A CBAM certificate is a tradable unit that represents one tonne of CO₂-equivalent emissions embedded in imported goods subject to the Carbon Border Adjustment Mechanism.During the CBAM permanent phase, EU importers must purchase and surrender CBAM certificates annually to account for the emissions associated with their imports. Certificate prices are linked to the average EU ETS carbon price, and the number of certificates required may be reduced if a carbon price was already paid in the country of origin. Accurate supplier emissions data helps minimize certificate costs.

Why are suppliers receiving more data requests from customers?

Due to increasing geopolitical uncertainty, shifting buyer expectations, and rapidly evolving regulations, suppliers are facing significantly more inquiries about their product and supply chain data. Some suppliers have seen up to a 500% year-over-year increase in requests. Managing this increase with manual processes or spreadsheets is no longer sustainable. AI-native technology and expert support are now essential for keeping up.

How does Assent support suppliers in managing complex data requirements?

Assent combines AI-native automation with real human guidance. The platform simplifies data submission, allows you to upload data once and share it with multiple customers, and provides clear workflows. Meanwhile, supplier success specialists offer hands-on support, clarify requirements, provide training, and deliver supplier-focused education, turning overwhelming demands into manageable steps.

What benefits do suppliers gain from using the Assent Sustainability Platform?

The platform acts as a central hub for responding to customer requests quickly and accurately. Assent specialists help suppliers get set up, navigate the system, configure catalogs and parts, and remove roadblocks. This leads to higher submission rates, fewer errors, and reduced workload, especially with tools like Request Manager, which allows suppliers to manage all data requests in one place, even from companies not using Assent.

How does Assent ensure ongoing success for suppliers?

Assent’s approach includes proactive issue resolution and continuous product improvement. Supplier success specialists help identify problems early, prevent repeated issues, and streamline workflows. They also gather real supplier feedback that guides updates to the platform, campaign strategy, and overall customer success approach, ensuring the system continually aligns with supplier needs.

EPA Issues Final Ruling on Long-Chain PFAS Action Plan

The U.S. Environmental Protection Agency (EPA) issued a final ruling on the safe use of per- and polyfluoroalkyl substances (PFAS) recently. It prohibits companies from bringing products containing long-chain PFAS in surface coatings to market in the U.S. without regulatory review and approval.

The ruling was issued under the Toxic Substances Control Act (TSCA), and includes review standards for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), two of the most commonly-used acids within the substance grouping. It prohibits companies from manufacturing, processing, or importing products that contain PFAS in a use case that could harm the environment or have negative impacts on human health, unless they have explicit review and approval from the EPA.

Learn how to quickly acquire PFAS substance data from your supply chain with Assent’s Reporting & Data Solution.

Navigating the PFAS Action Plan

The final ruling was issued as part of the PFAS Action Plan. Passed in February 2019, the plan brings multiple U.S. agencies together to identify and regulate the substance grouping’s harmful use cases. Although the substances can occur in a broad range of product types, it generally impacts companies that manufacture products within the following categories:

Ski wax
Carpeting and upholstery
Furniture
Electronics
Household appliances

Any products within these categories that contain certain PFAS chemicals (including PFOS and PFOA) can no longer be manufactured, imported, produced, or sold in the U.S. without explicit testing, review, and approval to identify and address any associated risks.

The program introduces a broad range of short and long-term solutions, providing companies with media, research, and risk communication to better understand, identify, and manage negative use cases. In addition to the supplemental proposal to regulate long-chain PFAS in surface coatings (to which this final ruling applies), the EPA has issued:

Preliminary determinations to regulate PFAS in drinking water.
Validated methods for accurate testing.
Guidance on addressing groundwater contaminants.
$4.8 million USD to fund new research on the use of PFAS in agriculture.
A notice to engage the public to comment on the inclusion of PFAS in the Toxics Release Inventory.

The final ruling on long-chain PFAS in surface coatings marks the latest in this long string of initiatives.

What This Means for Your Company

This ruling has a broad impact on global electronics and appliance manufacturers. In the past, companies shipping into California or the European Union (EU) may have acquired some PFAS data to meet requirements driven by the Stockholm Convention on persistent organic pollutants (POPs), and by other state and regional market access regulations, such as the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation, the European Union (EU) POPs Recast Regulation, and the California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65).

However, the regulations above either limit usage to a safe threshold, or create the requirement to include warning labeling with the products. Only companies with full transparency into their product composition will be able to quickly evaluate their supply chain for any parts that contain PFAS and secure approval in a timely fashion.

Evaluate your risk under any hazardous substance requirement by acquiring full materials disclosures for each product you place on the market.

Companies placing products on the EU market have an additional imperative to acquire data on PFAS. The EU POPs Recast Regulation is one of the 70 market access requirements targeted by EU enforcement officials in the EU Market Surveillance Regulation. In addition to the creation of a centralized enforcement database, the regulation gives EU enforcement officials the ability to share information across the full regulatory spectrum for any articles placed on the EU market.

The Assent Sustainability Platform can help you acquire the data you need to determine which of your products are in scope of the EPA’s final ruling on long-chain PFAS in surface coatings. We also have the regulatory expertise to help you keep pace with broad regulatory priorities as they expand and mature under such legislation.

For more information, contact our experts today.

Cally Edgren

Vice President, Regulatory & Sustainability

Cally is a proven compliance program leader with experience developing, communicating, and executing company goals and strategies. She is a subject matter expert on product Read More

Cally Edgren | Vice President, Regulatory & Sustainability

Cally is a proven compliance program leader with experience developing, communicating, and executing company goals and strategies. She is a subject matter expert on product materials compliance as well as market access certifications and has a background in program and process development to support...