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Effective January 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) transitioned from a reporting requirement to an actual payment obligation. For the fasteners industry, this means a structural change in cost structure, administrative obligations, and risk management within the import chain. For us, as an importer of fasteners, this means we must not only report emissions — as we have been doing for two years now — but also purchase and submit CBAM certificates for all goods imported from January 1, 2026 onward. However, calculating the exact costs of this is currently still a major challenge. As an importer and distributor, we want to provide the market with clear information about what CBAM entails and how we handle it.
CBAM is a European regulation aimed at taxing CO₂ emissions from the production of goods equally, regardless of whether they take place within or outside the EU. The regulation was initially designed for raw materials such as steel, aluminium and energy, but was expanded to include fasteners as a downstream product at the end of 2022.
The mechanism imposes a carbon-related levy on goods imported into the EU, based on the embedded CO₂ emissions generated during production. The goal is to prevent so-called "carbon leakage": production relocating to countries with less strict climate regulations. For fasteners, the majority of these direct emissions arise in the steel production chain (from mineral to steel and from steel to threat).
This is a significant change for our sector. Almost all global fastener production (and the steel used for it) takes place outside the EU. There is barely any production capacity available within Europe for standard fasteners. In practice, CBAM does not protect European production, but it does lead to a structural cost increase in the supply chain. CBAM is a legal EU requirement and applies sector-wide to all importers of fasteners.
During the transition period — October 2023 to December 2025 — only a reporting obligation applied. From January 1, 2026, a payment obligation also applies. From January 2026, EU importers are required to:
This makes CBAM a structural cost component within the fastener import chain.
The impact of CBAM varies significantly by product group. Products with a low intrinsic value (such as nuts, bolts, and washers) are relatively more affected. For these items, the CO₂ component represents a larger portion of the total cost. Higher-quality fastening solutions generally have a lower relative CBAM impact.
Although the legislation has been adopted, its implementation is still under development. This makes the final cost price development less predictable than before. Currently, the following uncertainties are at play:
Hoenderdaal has been actively preparing for the implementation of CBAM for some time now. We have met all reporting requirements since the start of the transition period and have adapted our internal processes accordingly. Our approach includes:
CBAM requires a structured approach to internal processes and governance. Importers of fasteners must have:
Non-compliance can lead to financial penalties and restrictions on import activities. The responsibility and risks lie entirely with the EU importer.
Hoenderdaal supports the pursuit of sustainability and transparency in international trade chains. At the same time, we note that the expansion of CBAM to fasteners primarily leads to additional administrative burdens, financial risks, and higher costs for European buyers in practice; without creating a level playing field or substantial European production capacity in our sector.
CBAM structurally changes how the import of fasteners is regulated and priced. It is realistic to expect that this will lead to higher costs in our industry in the coming years.
Together with NEVIB and the European Association of Fasteners Importers, we are committed to bringing this issue to the attention of European legislators. In the press release below, EFDA explains our position and our appeal to the EU.
CBAM is a complex and technical issue with structural consequences for the European fastener market. As a reliable and future-proof partner, we take responsibility for its implementation, while remaining critical of feasibility and proportionality.
Do you have questions about the impact of CBAM on your specific situation? We would be happy to discuss this with you.
