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Explainer

Does my import fall under CBAM?

Adopted 2026-06-14 ยท ≈ 2 min read ยท Dirk Baaijen

CBAM covers imports of iron/steel, aluminium, cement, fertilisers, electricity and hydrogen. Above 50 tonnes a year you need declarant status; below that you are exempt.

Short answer: Your import falls under CBAM if it concerns covered goods โ€” iron/steel, aluminium, cement, fertilisers, electricity or hydrogen โ€” and you import more than 50 tonnes of CBAM goods per year. Below that threshold you are exempt.

Which goods and which threshold?

CBAM (Regulation (EU) 2023/956) has applied in its definitive form since 1 January 2026. The mechanism puts a carbon price on imports of carbon-intensive goods: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. If you bring none of these goods into the EU, your import does not fall under CBAM.

If you do fall within these categories, the volume determines your obligations. Under the Omnibus simplification a de-minimis threshold applies: importers who bring in fewer than 50 tonnes of CBAM goods per year are exempt. Anyone above that threshold falls under the full regime.

What must I arrange if I fall under it?

Importers caught by the full regime need 'authorised CBAM declarant' status. The application for this status must be submitted no later than 31 March 2026. Without it you may no longer import the goods concerned.

As an authorised declarant you buy CBAM certificates covering the embedded CO2 emissions of your imported goods. For this you need reliable emissions data: the emissions released during the production of the goods. You request that data from your suppliers, so start that conversation early and agree how and when the figures will be delivered to you.

When must I file a declaration?

The first annual declaration under the definitive regime is due on 30 September 2027. In it you report the imported quantities, the associated embedded emissions and the certificates surrendered. From now on, keep track of your import volumes and the emissions data you receive, so that you can file a well-supported declaration at that point.

Read the main file: CBAM: the carbon border levy on imports. Or take the Transport & Logistics scan.

Sources

  1. https://eur-lex.europa.eu/eli/reg/2023/956/oj
    Regulation (EU) 2023/956 (CBAM); definitive regime from 1 January 2026.

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CBAM: the carbon border levy hits imports and chain logistics

Since 1 January 2026 the definitive CBAM regime (Regulation (EU) 2023/956) applies: importers of steel, aluminium, cement, fertilisers and more must become an 'authorised CBAM declarant' and buy certificates for embedded COโ‚‚. What that means for import and chain logistics.

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CBAM: does the 50-tonne exemption apply to me?

The CBAM exemption applies if you import less than 50 tonnes of CBAM goods (iron/steel, aluminium, cement, fertiliser, hydrogen) per year. Above that you need declarant status and must buy CBAM certificates.

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How do I become an authorised CBAM declarant?

Importers of CBAM goods have needed authorised CBAM declarant status since 1 January 2026. The application was due by 31 March 2026; you then buy certificates and file an annual declaration.

Dirk Baaijen

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