Which goods fall under CBAM?
CBAM applies to imports of iron/steel, aluminium, cement, fertilisers, electricity and hydrogen. Importers below 50 tonnes per year are exempt under the Omnibus de-minimis rule.
Download the regime cheat sheet (PDF) ↓
Short answer: CBAM covers imports of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The definitive regime applies from 1 January 2026 under Regulation (EU) 2023/956.
Which product groups are covered?
CBAM (the Carbon Border Adjustment Mechanism) targets carbon-intensive goods brought into the European Union. Six categories are in scope:
- iron and steel
- aluminium
- cement
- fertilisers
- electricity
- hydrogen
For each category, the CO2 embedded in production must be determined. Importers request emissions data from their suppliers outside the EU. That emissions data forms the basis for the number of CBAM certificates that must later be purchased.
What does this mean for importers?
Anyone importing these goods needs 'authorised CBAM declarant' status. The application must be submitted no later than 31 March 2026. Under the definitive regime, importers buy CBAM certificates matching the embedded CO2 of their imports. The first annual declaration is due on 30 September 2027.
In practice, collecting and verifying emissions data from foreign suppliers is the heaviest obligation. Start early, because without reliable data an accurate declaration is not possible.
The de-minimis threshold
Not every importer falls under the full set of obligations. Thanks to the Omnibus simplification, importers bringing in less than 50 tonnes of CBAM goods per year are exempt. Those above the threshold are fully subject to the regime. It therefore pays to map your annual volumes per goods category precisely.
Read the main file: CBAM: the carbon border levy on imports. Or take the Transport & Logistics scan.
Sources
- 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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