Some companies are exploring structured responses that integrate CBAM compliance with broader supply chain and climate strategies. While limited, practices include: –Mapping suppliers of in-scope goods by origin, volume and embedded emissions –Transitioning to suppliers of materials with lower carbon footprints; investing in digital MRV systems to centralize emissions data and comply efficiently –Forming cross-functional CBAM teams supported by governance structures, external consultants or specialized software –Updating contracts to include emissions reporting and CBAM-compliance clauses –Applying internal carbon pricing, ideally aligned with the EU CBAM Scope, to stress-test costs and inform operational decisions During the transition to new systems and processes for collecting and analysing emissions data, companies may use default emissions factors when actual data is unavailable.37 Deloitte notes importers can initially report default values or use alternative monitoring if supplier data is missing. While this provides a short-term compliance pathway, it can create risks in energy-intensive industries, since default values are often higher. This may inflate reported carbon costs, distort competitiveness by making some imports appear more carbon-intensive than they actually are and reduce incentives for suppliers to improve accuracy. Investing in robust MRV systems is essential to avoid such cost penalties and credibility gaps. Based on the case studies and focus group meetings organized for this paper, companies have reported forming cross-functional CBAM teams to ensure compliance, supported by transparent governance, external consultants or specialized software. These compliance tools automate data requests from suppliers and implement fall-back strategies, reducing manual errors and associated risks.38 To better anticipate carbon costs, companies apply internal carbon pricing in two ways: hypothetically, as a planning and accounting tool, or concretely, by assigning a cost to each unit of emissions. By mapping Scope 3 emissions and integrating carbon tracking into their reporting, businesses can facilitate a smoother transition and reduce uncertainty. As regulatory expectations tighten, these internal systems are evolving from compliance tools into competitive enablers, allowing companies to anticipate cost exposure and differentiate in carbon-sensitive markets. An additional concern in this transition is the risk of “carbon poverty”, where smaller companies, especially micro, small and medium-sized enterprises (MSMEs) in developing economies, lack the financial or technical capacity to measure and report emissions with the same rigour as multinationals. These companies may face exclusion from international supply chains, reinforcing inequalities. Addressing this requires global cooperation, public–private partnerships, capacity-building and technology transfer, so that all suppliers can participate in low-carbon trade. The diversity of private-sector responses provides a foundation for shaping carbon strategies. The strategy playbook provided in Section 3 outlines actionable pathways for companies navigating BCA-aligned procurement, risk management and emissions disclosure. Under a BCA, companies respond to border fees by innovating with low- carbon inputs and processes worldwide. Early adopters can gain a competitive advantage; for example, McKinsey, by analysing a European automotive OEM, finds that “companies reducing supply chain emissions can significantly increase EBIT by 15 to 50% by 2030”.39 To understand how major players in carbon- intensive sectors are adapting, in-depth case studies of leading companies in BASIC countries have been conducted, highlighting strategic innovations and operational approaches that illustrate paths towards compliance and competitiveness. “Companies reducing supply chain emissions can significantly increase EBIT by 15 to 50% by 2030.” Climate and Competitiveness: Border Carbon Adjustments in Action 10

Climate and Competitiveness Border Carbon Adjustments in Action 2025