Tariff Updates
CBAM in 2026: What EU Importers Must Do and Pay
Published · 8 min read
CBAM — the EU's Carbon Border Adjustment Mechanism — moved into its definitive period on 1 January 2026. If your imports of CBAM goods — iron and steel, aluminium, cement, fertilisers, hydrogen or electricity — exceed the 50-tonne annual threshold, you must be an authorised CBAM declarant, and you will buy CBAM certificates from 1 February 2027 to cover the embedded emissions of your 2026 imports, surrendering them by 30 September 2027.
For most goods the 2026 charge is small, because it is phased in as EU carbon-market free allocation is phased out. But it grows every year to full exposure in 2034, and the paperwork obligations apply now. Here is what CBAM covers, who has to act, how the cost is set, and how to build it into a landed-cost comparison.
What Is CBAM and Which Goods Does It Cover?
CBAM puts a carbon price on the greenhouse-gas emissions embedded in certain imports, matching the price EU producers pay under the EU Emissions Trading System (ETS). It covers six sectors:
| Sector | Examples of covered goods |
|---|---|
| Iron and steel | Flat-rolled products, bars, tubes, and certain downstream articles such as screws and bolts |
| Aluminium | Unwrought aluminium, sheet, foil, tubes and certain articles |
| Cement | Clinker and cements |
| Fertilisers | Nitrogen-based fertilisers, ammonia, nitric acid |
| Hydrogen | Hydrogen |
| Electricity | Imported electricity |
Coverage is defined by CN code in the CBAM Regulation annex, so check your CN/TARIC classification against the official list rather than the product name.
Who Has to Comply in 2026? The 50-Tonne Threshold
The 2025 CBAM simplification package introduced a single mass-based threshold: importers bringing in 50 tonnes or less of CBAM goods per calendar year are exempt. According to the European Commission, the threshold takes about 90% of importers out of scope while still covering around 99% of embedded emissions (ICAP summary).
Above the threshold:
- You (or your indirect customs representative) must hold authorised CBAM declarant status.
- Importers who applied by 31 March 2026 could keep importing while their application was being processed.
- You must collect embedded-emissions data from your suppliers' installations, or fall back on default values.
Track your cumulative tonnage across the year: the threshold is counted per importer per calendar year, so a run of large autumn shipments can take you over it. Hydrogen and electricity are treated differently from the tonnage-based goods, so check the regulation if you import either.
How Much Will CBAM Cost?
The CBAM cost for a shipment is, in simplified terms:
CBAM certificates required = embedded emissions − free-allocation adjustment − carbon price already paid in the country of origin
Three factors keep the 2026 charge low but rising:
- Free allocation phase-out. The adjustment mirrors free allocation under the EU ETS, which falls each year (table below). In 2026 it still covers 97.5% of the benchmark-based allocation, so only a small share of emissions is chargeable.
- Certificate price. Certificates for 2026 imports are priced at the quarterly average of EU ETS auction clearing prices; from 2027, at the weekly average (European Commission, CBAM definitive regime).
- Default values carry a mark-up. If you cannot get real emissions data, default values apply with a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 — real supplier data is usually cheaper.
| Year | Share of free allocation still applied (CBAM factor) |
|---|---|
| 2026 | 97.5% |
| 2027 | 95% |
| 2028 | 90% |
| 2029 | 77.5% |
| 2030 | 51.5% |
| 2031 | 39% |
| 2032 | 26.5% |
| 2033 | 14% |
| 2034 | 0% (full CBAM exposure) |
The practical takeaway: a steel or aluminium supplier that looks cheapest today may not be cheapest in 2030, when roughly half of the embedded emissions become chargeable. Emission intensity is becoming a sourcing variable.
What Are the Key CBAM Dates?
| Date | Milestone |
|---|---|
| 1 Oct 2023 – 31 Dec 2025 | Transitional period: quarterly reporting only, no payment |
| 1 Jan 2026 | Definitive period starts; 50-tonne threshold applies |
| 31 Mar 2026 | Deadline to apply for authorised declarant status and keep importing during review |
| 1 Feb 2027 | CBAM certificates go on sale on the central platform |
| 30 Sep 2027 | First annual CBAM declaration and certificate surrender for 2026 imports |
What Should EU Importers Do Now?
- Measure tonnage. Add up 2026 imports of CBAM goods by CN code to see whether you cross 50 tonnes.
- Secure declarant status if you are above the threshold, or make sure your customs representative holds it.
- Request installation-level emissions data from suppliers, verified where required — it is cheaper than marked-up defaults.
- Accrue the cost. Budget for certificates covering 2026 imports even though you buy them in 2027.
- Add CBAM to supplier comparisons for steel, aluminium and fertiliser inputs, alongside EU import duty and VAT.
How Does CBAM Fit Into Landed Cost?
CBAM is not a customs duty: it is not part of the customs value and it is not charged on the entry. It is a separate per-tonne carbon cost that belongs in your landed cost as its own line, next to duty, freight and fees. Compare origins on that full number — a low-carbon producer with a higher unit price can win once CBAM is counted, and that advantage widens every year to 2034.
Note that ImportCostPro reports do not yet include CBAM certificate costs; model them separately using the steps above.
ImportCostPro's EU analysis ranks 20+ supplier countries by landed cost to your EU port with TARIC duty, GSP/EBA and FTA preferences built in. For definitions of CBAM terms, see the import glossary.
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Frequently Asked Questions
- When did the CBAM definitive period start?
- On 1 January 2026. The transitional period from October 2023 to December 2025 only required quarterly reporting. From 2026, importers above the 50-tonne threshold must be authorised CBAM declarants and will surrender CBAM certificates for their 2026 imports by 30 September 2027.
- What is the CBAM 50-tonne threshold?
- Importers who bring in 50 tonnes or less of CBAM goods in a calendar year are exempt from CBAM obligations. The threshold was introduced by the 2025 CBAM simplification package; the European Commission estimates it exempts about 90% of importers while still covering about 99% of embedded emissions.
- Which products are covered by CBAM?
- Six sectors: iron and steel (including certain downstream articles such as screws and bolts), aluminium, cement, fertilisers, hydrogen and electricity. Coverage is defined by CN code in the CBAM Regulation, so check the official list against your product's classification.
- When can importers buy CBAM certificates?
- CBAM certificates go on sale from 1 February 2027 on the EU's central platform, covering emissions embedded in goods imported during 2026. For 2026 imports the price is the quarterly average of EU ETS auction clearing prices; from 2027 it is the weekly average.
- How much does CBAM cost in 2026?
- Relatively little per tonne, because the obligation is reduced by an adjustment mirroring EU ETS free allocation, which still covers 97.5% in 2026. The chargeable share rises every year — about half of embedded emissions by 2030 and all of them by 2034 — and default emission values carry a 10% mark-up in 2026, rising to 30% from 2028.