IMPORTANT FOR UZBEK EXPORTERS TO THE EU
2026-01-11 12:00:00 / News
The European Union is discussing a mechanism for the temporary and even retroactive removal of goods from CBAM
In early January, the European Commission published clarifications on the draft new Article 27a of the CBAM Regulation (Carbon Border Adjustment Mechanism - a mechanism for carbon adjustment at the border). These provisions have not yet been adopted, but they are already being actively discussed within the European Union and may significantly affect exports to Europe.
What is CBAM?
CBAM is an EU mechanism that introduces a charge on the “carbon footprint” of imported products in order to level the playing field between European and non-European producers. It applies to the following products:
iron and steel and steel products
aluminium
fertilizers (ammonia, nitrogen-based and others)
cement
electricity
For Uzbek exporters, this means additional reporting requirements and, starting from 2027, financial obligations.
What does Article 27a propose?
The draft Article 27a introduces a so-called “emergency brake” mechanism:
1. Temporary removal of goods from CBAM
If the EU considers that the inclusion of a specific product in CBAM:
leads to a sharp increase in prices
causes serious and unforeseen damage to the EU internal market
The Commission may temporarily exclude this product from the CBAM list.
2. Possibility of retroactive application
The key point is that the decision may have retroactive effect - that is, it may apply not from the date of publication, but from the moment when, in the EU’s view, “critical conditions” arose.
3. Potential reimbursement of CBAM certificates
If a product is excluded from CBAM retroactively, the issue of reimbursing the cost of CBAM certificates already purchased by importers may arise.
Why is this important now?
2026 is the final year of the CBAM transitional period (for now, reporting only).
From 2027, EU importers will start actually purchasing CBAM certificates, which means direct costs.
The discussion of Article 27a indicates that the rules may change already during the rollout of the system.
For exporters from Uzbekistan, this creates a window of regulatory risk:
contracts, pricing and carbon footprint calculations may require revision.
Which Uzbek sectors are under the greatest focus?
In the context of CBAM and Article 27a, the following sectors are of greatest interest:
mineral fertilizers and ammonia
aluminium products
iron and steel products and rolled steel
energy-intensive chemical products
What is recommended for exporters?
Experts already recommend that exporters:
closely monitor EU decisions related to Article 27a
build flexibility on CBAM-related costs into export contracts
maintain accurate records of emissions and production data
be prepared for possible rule adjustments and reimbursement of payments
Conclusion
CBAM remains a key factor for access to the EU market.
However, the discussion of Article 27a shows that even within the European Union, the risks of sharp price increases are understood, and temporary and even retroactive changes to the rules are being considered.
For Uzbek exporters, this is a clear signal:
it is necessary not only to comply with CBAM requirements, but also to closely follow the evolution of the rules in order to avoid excessive costs.