CBAM 2026: what importers of steel, aluminium and fertilisers must do
Reviewed:
The Carbon Border Adjustment Mechanism (CBAM) puts a price on the emissions embedded in certain imports. Since 1 January 2026 it is in its definitive period: 2026 imports already create an obligation to buy certificates, not just to report.
Legal text
Regulation (EU) 2023/956, Article 2a(1) (inserted by Regulation (EU) 2025/2083)
An importer, including any importer with the status of an authorised CBAM declarant, shall be exempted from the obligations under this Regulation, where the net mass of the imported goods in a given calendar year does not cumulatively exceed the single mass-based threshold laid down in point 1 of Annex VII […]. That threshold shall apply to the total net mass of goods under all CN codes aggregated per importer and per calendar year. […]
Goods covered
Iron and steel (Combined Nomenclature chapter 72 and part of chapter 73), aluminium (part of chapter 76), cement, fertilisers, hydrogen and electricity.
The 50-tonne threshold
Regulation (EU) 2025/2083 replaced the old value threshold with an annual mass threshold. Anyone importing more than 50 net tonnes of CBAM goods in a year, adding up all their imports, needs authorised declarant status. Electricity and hydrogen have no threshold.
If the threshold is crossed during the year, the obligations cover everything imported that year, including the first 50 tonnes, and importing above the threshold without authorisation is penalised. An indirect customs representative may act as the authorised declarant or decline and leave the obligation with the importer.
Key dates
The 2026 price is published quarterly based on EU Emissions Trading System allowance prices (EUR 75.36 per tonne of CO₂ in the first quarter). From 2027 it will be published weekly.
- 1 January 2026: definitive period begins.
- 1 February 2027: certificate sales open on the Commission's central platform.
- 30 September 2027: first annual declaration and surrender of certificates for 2026 imports.
Data to ask your supplier for
Verified actual emissions from the production installation. Without that data default values apply, which usually work out more expensive.
How we help
As customs representatives, before import we check whether the goods are subject to CBAM and whether the importer has an authorised declarant number, so clearance is not blocked.
The annual declaration and the purchase of certificates are the authorised declarant's responsibility.
Ask us about your shipmentOfficial sources
General information, not legal advice. Regulations change often, so always check the current text in the official sources.