In November 2025, the CAKE/KOBiZE analytical team published the report "CBAM and Budgetary Revenue. Prospects for the EU and Poland," which directly asks a question rarely discussed openly until now: how much money will CBAM actually bring to the budgets of the European Union and individual member states, including Poland, and what impact these funds will have on the shape of future climate policy and business regulations. The document is not just another study on the "CBAM idea." It is a rigorous attempt to calculate the revenues that the border mechanism could generate under various assumptions regarding carbon prices, sectoral scope, and third-country reactions.
The authors proceed from a simple yet crucial premise: the CBAM is not only regulatory but also fiscal in nature. 75 percent of revenues are to be allocated to the EU budget, with the remaining 25 percent remaining in national budgets. Behind the scenes, a strategic game is being played for a new, stable source of revenue that will finance the energy transition, support funds for industry, and the servicing of the EU debt. This financial dimension is crucial because it directly influences the political pressure to not only maintain the mechanism but also expand rather than reduce it in the medium term.
The report's methodology is based on two main axes. First, it analyzes the current scope of the CBAM, which includes cement, iron and steel, aluminum, fertilizers, and electricity. Depending on the sector, direct emissions or both direct and indirect emissions are considered. Second, the authors construct an expansion scenario in which the mechanism covers not only indirect emissions for steel and aluminum in 2030, but also a number of additional energy-intensive sectors (chemicals, refinery products, plastics, paper, other metals) and selected downstream products, such as metal products, electronics, vehicles, transport equipment, and some agricultural products. Importantly, for processed products, emissions "one level up" the supply chain are calculated, not the full carbon footprint, reflecting real-world administrative constraints and data availability.
The second axis comprises assumptions regarding carbon prices outside the EU. The report does not assume a single "world" scenario, but considers three variants: from the status quo, in which carbon pricing systems outside the EU develop moderately and the gap to the EU ETS remains high, through moderate convergence (prices in third countries reach 25 percent of the EU ETS price in 2030 and 50 percent in 2035), to strong convergence, where these ratios reach 50 and 75 percent, respectively. The higher the carbon price outside the EU, the greater the share of carbon costs already "embedded" in the producer's product and can be deducted from the CBAM obligation, and therefore the lower the revenues from the border mechanism. At the same time, the price of EUA allowances is assumed to be EUR 123/t CO₂ in 2030 and EUR 147/t in 2035, the phasing out of free allowances in the ETS by 2034 and a moderate decrease in the emission intensity of production in imports.
Against this backdrop, the scale of the potential revenues becomes clear. With the current, narrow CBAM range, total revenue for the EU in 2030 is estimated at €5-9 billion and in 2035 at €6-22 billion, depending on how closely the world aligns with European carbon prices. In the extended scenario, the ranges increase dramatically: €16-31 billion in 2030 and €20-75 billion in 2035. This level already significantly changes the structure of EU budget resources and creates a strong incentive for European institutions to take such expansion seriously. For Poland, with the proportions of the import structure maintained, this means EUR 0,4-0,8 billion in 2030 and EUR 0,5-1,9 billion in 2035 in the baseline scenario, while with the extended CBAM we are talking about EUR 1,1-2,1 billion in 2030 and EUR 1,4-5,3 billion in 2035. Poland's share in the total EU CBAM revenues stabilizes at the level of 7-8 percent.
The distribution of the burden between countries of import origin is also interesting. Currently, the dominant import destinations are classic steel, fertilizer, and aluminum imports, such as Russia, Turkey, and Ukraine. With the extension of the CBAM to chemicals, refinery products, and broad categories of processed goods, the burden of the carbon tax shifts toward countries with large exports of highly processed goods, primarily China and the United States. In the extended scenario, China's share of the EU's total CBAM revenue increases from approximately 9 percent to over 20 percent, and in the case of Poland, from approximately 11 percent to approximately 25 percent. This means that the border mechanism begins to realistically assess the carbon footprint not only at the source of the raw material, but also in the global value chains where European customers purchase complex finished products.
The report's authors honestly point out the limitations of their approach: they do not model the market's reaction to the cost of CBAM, do not account for potential declines in import volumes or trade diversion, and do not analyze the macroeconomic impact or indirect tax revenues. The goal is therefore to demonstrate the "fiscal potential" of CBAM and compare scenarios rather than to provide an accurate accounting forecast. From a business perspective, however, this does not change the key conclusion: from Brussels' perspective, CBAM is not only a climate tool but also a significant source of revenue, and any step towards expanding its product scope will have a solid budgetary justification.
What does all this mean for businesses, especially in Poland? The CBAM is here to stay and will likely be expanded. Currently, it affects importers of steel, aluminum, cement, fertilizers, and electricity. In the coming years, a realistic scenario is for the mechanism to also cover chemicals, refined products, plastics, paper, and a wide range of processed products, from metal components to vehicles and electronics. For importers, this means building lasting, systemic competencies in supply chain carbon management: acquiring data from non-EU producers, verifying its quality, assessing the risk of countries of origin, conducting scenario-based CBAM cost calculations, and, equally importantly, making purchasing decisions that take into account future carbon tax burdens, not just the current commodity price.
For the Polish economy as a whole, the report carries another important message. In the extended scenario, the CBAM promotes a model in which it becomes more profitable to develop processing and production of higher-value-added products within the EU, while simultaneously limiting the import of high-emission semi-finished products and components. In other words, the system encourages the shortening and "networking" of supply chains within the EU and investment in decarbonization among European producers. Companies that begin organizing their emissions data today, building relationships with suppliers who understand the CBAM, and incorporating carbon costs into their business models will be in a significantly stronger negotiating and competitive position when the border mechanism enters its full implementation phase and its scope is expanded beyond today's narrow CN.
