CBAM obligations for importers

Short answer: The definitive phase of the Carbon Border Adjustment Mechanism (CBAM) applies from 1 January 2026. EU importers bringing in more than 50 tonnes of CBAM goods per year must be registered as authorised declarants and submit an annual CBAM declaration. Certificates covering 2026 imports will be purchased via the central platform, which opens on 1 February 2027; the first surrender and declaration must be completed by 30 September 2027.

CBAM obligations for importers

Who is covered? EU importers — or their indirect customs representatives — importing more than 50 tonnes (net mass, cumulative) of CBAM goods per calendar year must apply for authorised CBAM declarant status with their national competent authority. The 50-tonne threshold is a de minimis exemption: the Commission estimates it excludes approximately 90% of importers while keeping 99% of embedded emissions within scope. Electricity and hydrogen are not subject to this threshold.

Which goods? CBAM applies to: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen — including certain precursors. The applicable sector codes and goods are listed in Annex I to Regulation (EU) 2023/956.

Certificate price (Article 21) The Commission sets the price as the weighted average of the auction clearing prices of EU ETS allowances (EU ETS 1), calculated on the basis of publicly available auction data and published by Commission Implementing Regulation (EU) 2025/2548. In 2026, one quarterly price is published in the first calendar week following each quarter-end. From 2027 onwards, weekly prices will be published. The Q1 2026 price was €75.36 per certificate. The price basis is therefore the weighted average of auction clearing prices — not a single closing price.

Purchase and buffer obligation (Article 22) Certificates are purchased through the common central CBAM platform (Art. 20), which opens on 1 February 2027. The quarterly buffer obligation under Article 22(2) — holding certificates equal to at least 50% of the embedded emissions of all goods imported since the start of the calendar year — applies from 2027 onwards. No interim buffer obligation applies for the 2026 import period; the full required volume is settled at the first annual declaration.

First declaration and surrender By 30 September 2027, each authorised declarant must:

1. Submit an annual CBAM declaration covering verified embedded emissions of all CBAM goods imported during 2026;
2. Surrender a corresponding number of CBAM certificates.

Embedded emissions for which a carbon price has already been paid in the country of production may be deducted.

Regulatory framework The legal basis is Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083 (October 2025 simplifications). Certificate pricing is governed by Commission Implementing Regulation (EU) 2025/2548. Authorised declarant requirements are set out in Commission Implementing Regulation (EU) 2025/486.