Does CBAM apply to your imports?

The Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) puts a carbon price on the greenhouse gas emissions embedded in certain goods imported into the EU, at the price of the EU Emissions Trading System. Goods made in the EU and imported goods then carry a comparable carbon cost.

Since 1 January 2026, only authorised CBAM declarants may import these goods, and they buy and surrender CBAM certificates for the embedded emissions.

• Iron and steel (chapter 72), including tubes, structures, containers, screws and bolts (7301–7311, 7318, 7326);
• Aluminium: unwrought aluminium and aluminium products (7601, 7603–7614, 7616);
• Cement and clinker (2523);
• Fertilisers: ammonia, nitric acid, nitrogen and mixed fertilisers;
• Hydrogen and electricity.

Not covered: steel and aluminium scrap, ferro-silicon and most other ferro-alloys, phosphate and potash fertilisers, and products such as machinery or appliances.

A Commission proposal would add about 180 steel- and aluminium-intensive products from 1 January 2028. It has not been adopted.

An importer is exempt when the net mass of all CBAM goods it imports in a calendar year, across all customs codes together, does not exceed 50 tonnes. The importer declares the exemption in the customs declaration.

• Hydrogen and electricity are not counted: they are always covered.
• Once you exceed 50 tonnes, all goods imported that year are covered, not just the excess.
• Splitting imports to stay below the threshold is disregarded and penalised.

The Commission reviews the threshold every year; in 2026 it stayed at 50 tonnes.

The importer established in the EU applies before importing CBAM goods above the threshold. An indirect customs representative can be the authorised declarant instead, and must be when the importer is not established in the EU.

• Importers who applied by 31 March 2026 may keep importing until the authority decides.
• Importing without authorisation costs three to five times the EU ETS penalty per tonne of embedded emissions.

The price follows the EU ETS auction price: the quarterly average for goods imported in 2026, and the weekly average from 2027. The Commission publishes the price; for Q3 2026 it was €82.32 per tonne of CO₂.

• Certificates go on sale on 1 February 2027.
• From 2027, you must hold certificates for at least 50% of the emissions in the year's imports so far at the end of each quarter.

You can declare the actual emissions of the installations that produced the goods, verified by an accredited verifier, or use the Commission's default values per customs code and country.

Default values carry a mark-up: 10% in 2026, 20% in 2027 and 30% from 2028 (1% for fertilisers). Verified actual data therefore usually costs less.

EU producers still receive some free emission allowances, and CBAM deducts the same share from what importers pay. That free allocation is phased out: CBAM covers 2.5% of the benchmark emissions in 2026, 48.5% in 2030 and 100% from 2034.

Emissions above the EU benchmark are paid in full from the start.

• 1 January 2026: the definitive period starts.
• 1 February 2027: CBAM certificates go on sale.
• From Q1 2027: the 50% holding requirement at the end of each quarter.
• 30 September 2027: first annual declaration and surrender of certificates, for 2026 imports.
• 1 November 2027: unused certificates for 2026 are cancelled.

Yes, if it was actually paid in the country of production, net of any rebate, and is certified and documented. With default values, only the Commission's default carbon prices can be used.

• Goods produced in Norway, Iceland, Liechtenstein and Switzerland are outside CBAM.
• Goods produced in the United Kingdom are covered when they enter the EU.

Your EU customers who import covered goods are the CBAM declarants, and they will ask you for the emissions embedded in them.