CBAM in 2026: A Strategic Inflection Point for Senior Leadership and Talent

Designed to level the playing field between EU producers, CBAM applies an emissions‑adjusted cost to imports of carbon‑intensive goods such as steel, aluminium, cement, fertilisers, electricity and hydrogen – many of which are key inputs or products within the EMEA chemicals industry. 

This shift effectively introduces a form of green tariff, intended to curb so‑called “carbon leakage” by ensuring that imported products face a comparable carbon cost to those manufactured within the EU. At the same time, the European Commission has signalled its intention to expand CBAM’s scope over the coming years to include certain downstream products, reinforcing the EU’s broader climate and industrial strategy. 

In this article I discuss how CBAM’s move into its definitive phase in 2026 is reshaping commercial priorities, governance expectations and the senior leadership. I also explore the talent capabilities organisations across EMEA’s Chemicals industry will need to compete in a carbon‑constrained global economy. 

Regulatory Purpose and Industry Response to CBAM 

CBAM is intended to reinforce the EU’s carbon pricing regime by aligning the carbon cost of imports with that faced by EU producers, alongside the gradual phase-out of free ETS allowances. As outlined by the European Parliament, the mechanism aims to preserve decarbonisation incentives while limiting competitiveness risks. 

At the same time, recent simplification measures – including a 50-tonne de minimis exemption – are designed to reduce the compliance burden for smaller importers without diluting the policy’s impact on carbon-intensive trade, which is particularly relevant for chemical intermediates and feedstocks. 

Nevertheless, as Carbon Market Watch has noted, industry support has become more qualified as full implementation approaches, with some heavy industrial and chemical producers now calling for delays or additional safeguards amid concerns over complexity and competitiveness. 

Geopolitical Uncertainty and Strategic Resilience 

Geopolitical uncertainty and rising protectionism are undoubtedly reshaping global trade, introducing volatility through tariffs, sanctions and shifting trade alliances. While these dynamics may influence the mechanics or timing of CBAM’s implementation, they do not alter its underlying strategic direction. Companies are increasingly operating in a world where trade, climate policy and geopolitics are structurally intertwined. 

For the EMEA chemicals industry, this reinforces the need to view CBAM as a leadership and organisational resilience issue. Carbon strategy must sit alongside geopolitical risk management, scenario planning and supply-chain redesign, requiring senior leaders who can navigate regulatory uncertainty while maintaining market access and long-term competitiveness. 

CBAM in 2026: Trade and Commercial Realities 

From a commercial perspective, CBAM is already altering how chemicals companies approach EU‑linked supply chains. 

First, emissions data has become a tradable requirement rather than a peripheral sustainability metric. Importers must obtain detailed, verified information on embedded emissions from non‑EU suppliers in order to comply with reporting and certificate obligations. As The Guardian has noted, this requirement is prompting many chemical exporters and processors to upgrade their carbon accounting capabilities simply to maintain access to the EU market. 

Second, CBAM is changing competitive dynamics. Firms operating in jurisdictions without robust carbon pricing mechanisms face additional costs when exporting to the EU, which may erode traditional price advantages. There has been growing resistance from some trading partners as a result, who view CBAM as protectionist in effect, if not in intent. 

Finally, the phased introduction of financial obligations creates a window for strategic adjustment rather than immediate shock. Recent analysis suggests that chemicals companies using this transition period to integrate carbon costs into pricing, sourcing and capital allocation decisions will be materially better positioned over the medium term. 

Senior Leadership and Talent Implications 

For boards and executive teams, CBAM is less a technical compliance issue than a catalyst for organisational change and several senior‑level talent implications are now becoming apparent for the EMEA chemicals sector. 

1. New Leadership Roles in Carbon Strategy

As CBAM reporting, verification and cost exposure increase, many chemicals organisations are recognising that traditional sustainability roles are insufficient. There is a growing need for senior accountability for carbon strategy, prompting the emergence of roles such as:  

• Chief Carbon Officer 
• Director of Carbon Strategy 
• Head of Climate Compliance 

These leaders bridge the gap between regulation, finance and operations, translating carbon exposure into strategic action across chemical production and distribution networks. 

2. Cross‑Functional Governance and Board Oversight

CBAM has implications for finance, legal, procurement, operations and public affairs. Embedding carbon considerations into core governance structures, including board‑level ESG or risk committees is becoming critically important as a result and demands senior leaders who are comfortable operating across functional boundaries and who can align decarbonisation with commercial outcomes within chemical operations and supply chains. 

3. Demand for Data and Carbon Accounting Expertise

Weak emissions data undermines both environmental integrity and business preparedness, which means senior hiring briefs should increasingly prioritise experience in carbon accounting, lifecycle analysis and regulatory reporting. These technical capabilities should now be viewed as strategic enablers, rather than specialist back‑office skills. 

4. Supply Chain and Procurement Leadership

CBAM places procurement at the centre of climate risk management. Senior procurement and supply chain leaders in chemicals companies must ensure that suppliers can provide reliable emissions data and meet evolving standards. Organisations that proactively build low‑carbon, transparent supplier networks are likely to enjoy greater resilience and pricing power over time. 

5. International Workforce and Location Strategy

For multinational organisations, CBAM also has implications for where leadership and expertise are located. As exporters outside the EU adapt to European carbon requirements, there is growing demand for leaders who understand both EU regulation and local operating realities. This is shaping executive mobility, regional leadership structures and succession planning across chemical production and distribution hubs in EMEA. 

Conclusion 

For the EMEA chemicals industry, the implications of CBAM are now becoming clear. While the technical details of the mechanism will continue to evolve, its strategic direction is firmly set. For chemicals producers, processors, and distributors operating across energy-intensive value chains, carbon exposure is becoming a core business variable. 

The decisive factor for chemicals organisations will not be regulation alone, but whether they have the senior leadership, governance structures and specialist talent required to respond effectively. This includes leaders who can: 

• Integrate carbon costs into commercial strategy 
• Oversee complex cross-border supply chains 
• Guide long-term asset and portfolio decisions in a carbon-constrained European market 

In this context, CBAM represents a defining leadership test for the EMEA chemicals sector, and those that address it proactively will be best positioned to sustain competitiveness through the transition ahead. 

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Adam Harman

Partner | Industrials | EMEA

E: adam.harman@weareprocogroup.com | T: +447990 306595

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