CBAM 2026: what changes for importers of steel, aluminium and cement
Definitive phase, 50-tonne threshold, authorised declarant and certificates: the practical guide to the Carbon Border Adjustment Mechanism.
CBAM (Carbon Border Adjustment Mechanism) is the mechanism through which the European Union puts a price on the carbon embedded in certain imported goods, such as steel, aluminium and cement. Since 1 January 2026 it has been in its definitive phase: anyone importing more than 50 tonnes a year of CBAM goods must be an authorised declarant and, from February 2027, buy certificates for the emissions embedded in their 2026 imports.
What CBAM is and why it exists
European companies covered by the Emissions Trading System (EU ETS) pay for the CO₂ they emit. Without a corrective measure, producing outside the Union under less stringent climate rules and then importing would be cheaper. CBAM rebalances this: the importer pays a price for the emissions embedded in the goods that is aligned with the ETS price, net of any carbon price already paid in the country of origin.
In parallel, the free ETS allowances allocated to European producers in the same sectors are gradually phased out. This is why the actual cost of CBAM rises year after year until 2034.
Which goods are covered
CBAM covers six sectors, identified by specific customs codes:
- cement;
- iron and steel, including many semi-finished products and some downstream products such as screws and bolts;
- aluminium;
- fertilisers;
- hydrogen;
- electricity.
The scope depends on the NC code of the goods, not on the company’s sector. An engineering company importing steel sections falls under CBAM even if it does not consider itself a steel company.
The 50-tonne threshold
With the simplification approved in 2025, CBAM provides a single mass-based exemption threshold: if in a calendar year you import no more than 50 tonnes of CBAM goods in total, you are exempt from the obligations for that year. The threshold does not apply to hydrogen and electricity, which are always subject to the mechanism.
The threshold is calculated on each importer’s annual total. If you are close to the limit, you need to monitor imports during the year: exceeding it removes the exemption for the current year.
Deadlines to note
| Date | What happens |
|---|---|
| 1 January 2026 | The definitive phase begins: above 50 tonnes a year, authorised CBAM declarant status is required. |
| 31 March 2026 | Deadline to apply for authorisation while continuing to import pending the decision. |
| 1 February 2027 | Sale and surrender of CBAM certificates for 2026 imports begin. |
| 30 September 2027 | Deadline for the first annual CBAM declaration, covering 2026 imports. |
The authorisation application is submitted through the European Commission’s CBAM Registry and assessed by the competent authority of the Member State in which the importer is established.
How much it costs: calculating the charge
The charge depends on three factors: the tonnes imported, the embedded emissions per tonne and the certificate price. The price is linked to ETS auction prices: for 2026 the quarterly average is used, from 2027 the weekly average.
Embedded emissions can be actual values, reported by the foreign producer and checked by an accredited verifier, or default values published by the Commission. Default values are deliberately conservative: using the supplier’s real data, when reliable, usually reduces the cost.
A simplified example: 100 tonnes of a steel product with embedded emissions of 2 tCO₂e per tonne amount to 200 tCO₂e. The number of certificates to surrender is obtained by applying to these emissions the share not covered by that year’s free allocation and subtracting any carbon price already paid in the country of origin.
CBAM and sustainability reporting
For the importer, the emissions embedded in purchased goods are Scope 3 emissions, category 1 (purchased goods and services). The data collected for CBAM is therefore the same data that improves the quality of the GHG inventory: instead of spend-based estimates, you have per-tonne values provided by producers.
The reverse is also true: if you sell to European customers who import, or supply components to companies subject to CBAM, expect requests for data on your products’ emissions. Having an emissions calculation that is traceable, document by document, makes these answers quick. Learn more in the guide to Scope 3 and the value chain.
Practical checklist
- Extract the NC codes of goods imported in the last twelve months and check which ones fall within the CBAM annexes.
- Add up the tonnes per calendar year and compare them with the 50-tonne threshold.
- If you are above the threshold, check that you have authorised declarant status or operate through an authorised indirect customs representative.
- Ask foreign suppliers for data on embedded emissions, specifying the production installation.
- Estimate the 2026 cost with both default values and real data, to understand how much it is worth working with suppliers on data quality.
- Link CBAM data to the GHG inventory, so the same work also serves the sustainability report.
