Author: Roeland De Sonnaville Date: 02/07/2026
Roeland De Sonnaville, Business Development Director at Fabory Group explains why fasteners are a CBAM blind spot.
Ask a manufacturing director what keeps them awake at night, and the EU Carbon Border Adjustment Mechanism rarely makes the top of the list. Energy costs, skills shortages, and the lingering effects of supply chain disruption dominate the conversation. Yet from January 2026, a regulation that has been quietly running in the background for over two years moves from reporting-only into financially payable territory. And a significant proportion of UK manufacturers, particularly those buying fasteners, fixings and other industrial components, have yet to understand that it is their problem too.
That blind spot is about to become expensive.
The misconception that matters most
The most common assumption I encounter when speaking with customers is that CBAM is "a supplier issue." The logic runs like this: the regulation applies at the point of EU import, so the importer pays, the supplier absorbs the cost, and the buyer carries on as before.
It's a reasonable assumption. It's also wrong in three important ways.
First, the regulation is structural. CBAM is not a temporary surcharge or a one-off carbon levy. It is a permanent EU mechanism designed to align the carbon costs of imported goods with those of goods produced within the EU, known as carbon leakage prevention. Since it became payable on 1 January 2026, the cost will apply every year to every shipment and will be recalculated annually as carbon certificate prices rise and the percentage of CBAM increases.
Second, the cost has nowhere to go but to the buyer. EU importers, the "declarants" under CBAM rules, are legally required to purchase and surrender CBAM certificates to cover the embedded emissions in their imported goods. The current reference certificate price is around €87 per tonne of CO₂, and EU policy projections suggest this could rise to €200–300 per tonne by 2034 as free allowances are phased out. For carbon-intensive complex goods like fasteners, where the vast majority of emissions sit upstream in steel smelting and rolling, that cost is material. It cannot be absorbed indefinitely by any importer operating on industrial margins.
Third, and this is the part most buyers haven't yet processed, CBAM compliance requires investment in systems and processes, as well as the management of the buyer's supply chain, which doesn't currently exist in most procurement files. Verified embedded emissions data. Evidence of carbon prices already paid. Information from non-EU installations that may or may not be ready to provide it. Without it, importers default to the highest possible emissions assumptions, and the cost passed through to the buyer reflects that worst-case calculation.
Why do fasteners sit in an awkward position?
The Department for Business and Trade's published guidance lists iron and steel, aluminium, cement, fertilisers and hydrogen as the categories currently in scope. Fasteners are not named explicitly and this is where the blind spot deepens. Fasteners fall under the iron and steel category by virtue of their classification codes, which means they are unambiguously within CBAM's reach despite not being on the headline list.
The supply chain reality compounds this. More than 85% of fastener volume consumed in the EU and UK is sourced from outside the EU, predominantly Asia. A significant proportion is still manufactured externally and supplied through European traders. There is no realistic scenario in which European fastener manufacturing capacity could absorb the displaced volume if buyers attempted to switch to EU-only sourcing. The structural exposure is unavoidable for the category as a whole.
This is not a problem buyers can procure their way out of. It is a problem they have to plan around.
What "leadership" actually looks like in this market
The temptation, for any supplier in a category facing structural cost increase, is to brace for difficult conversations and prepare defensive talking points. That's understandable, but it misses the larger opportunity. The suppliers that emerge from CBAM implementation in the strongest position will be the ones who treat this not as a pricing problem but as a partnership moment. The buyer who walked into Q2 2026 with no understanding of CBAM, no emissions data from their supply chain, and no plan for the cost trajectory ahead will be in a materially worse position than the buyer who has been guided through it.
Practical leadership in this category means several things. It means proactively mentioning CBAM in current commercial discussions rather than waiting for the first invoice to trigger the conversation. It means helping customers understand the difference between default emissions values and verified supplier data, and why the latter, where available, may materially reduce their long-term exposure as the regulatory framework beds in. It means recognising that the entire supplier base — European and non-European vendors alike — must take responsibility for reducing their carbon footprint, and that as a distributor, we are uniquely positioned to drive that conversation. CBAM gives us a lever: we can use it to ensure that carbon emissions decline over time and to shape our supply chain around partners who are both able and willing to invest in the necessary measures. That is not just compliance — it is an opportunity to build a supplier ecosystem that is genuinely more sustainable, and to offer customers a route to lower long-term exposure rather than simply passing on an unavoidable cost.
The window is narrower than it looks
The official compliance picture creates a false sense of timeline. Annual declarations for goods imported in 2026 aren't due until May 2027, which can read as a comfortable runway. It isn't. Verified emissions data takes time to gather. Accredited verifiers are still building capacity. Pricing negotiations happening today already need to reflect the 2026 reality, because contracts signed now will be in force when CBAM bites.
For UK manufacturers exporting into the EU, or for UK buyers importing fasteners and steel-based components into EU operations, the next six months are when this conversation needs to happen with suppliers who understand the regulations, can provide the data, and can guide the transition.
CBAM is not going away. The buyers who treat it as a strategic challenge rather than a procurement annoyance will come out of 2026 stronger than those who don't.