What EU importers must do under CBAM from 2026

Under Regulation (EU) 2023/956, goods in scope may be brought into the customs territory of the Union only by an authorised CBAM declarant. Following the October 2025 simplification (Regulation (EU) 2025/2083), a single mass-based de minimis threshold applies: an importer whose covered imports do not cumulatively exceed 50 tonnes of net mass in a calendar year is exempted from the mechanism's obligations (Article 2a). An operator that expects to exceed 50 tonnes in 2026 will therefore likely need to hold authorised declarant status before importing, granted by the national competent authority in its Member State. For transport and logistics the routing matters: the application is made by the importer or, where the Regulation so provides, by its indirect customs representative, so a forwarder clearing goods for a non-EU principal can itself end up being the authorised declarant. The threshold does not apply to electricity or hydrogen (Article 2a(4)), which remain in scope regardless of quantity. The Commission estimates the 50-tonne threshold exempts around 90% of importers — mostly SMEs and individuals — while keeping roughly 99% of embedded emissions within scope.

CBAM covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, together with certain precursors and downstream products. Coverage is defined by customs classification rather than commercial description: Annex I to Regulation (EU) 2023/956 lists the goods by CN code. For a compliance function this means scope should be assessed against the tariff codes on the customs declaration — a consignment is in scope if its CN code appears in Annex I, whatever it is called on the commercial invoice. Where a shipment mixes covered and non-covered lines, only the covered CN codes count towards both the 50-tonne threshold and the eventual certificate obligation.

The price of a CBAM certificate tracks the EU Emissions Trading System. Under Article 21 of Regulation (EU) 2023/956 the Commission sets it as the weighted average of the auction clearing prices of EU ETS allowances, with the calculation methodology laid down in Commission Implementing Regulation (EU) 2025/2548. Publication frequency steps up over time: for 2026 the Commission publishes four quarterly prices, one per calendar quarter, moving to weekly prices from 2027. The first quarterly price, for Q1 2026, was set at EUR 75.36 per certificate and published on 7 April 2026. Because the figure is a weighted average of auction results rather than a single closing quotation, cost planning should treat the certificate price as an administered EU-wide rate that resets on that published cadence, not as a spot-market quote a declarant can time.

Certificates are sold by Member States on a common central platform that the Commission establishes and manages; under Article 20 that platform operates from 1 February 2027. Holding requirements are staged. The quarterly obligation to hold certificates covering at least 50% of the embedded emissions of goods imported since the start of the calendar year applies only from 2027 (Article 22(2)); for the 2026 import year there is no interim quarterly buffer, so the full volume is settled at the first annual reckoning. By 30 September of each year the authorised declarant surrenders, through the CBAM registry, certificates matching the verified embedded emissions declared for the preceding year (Article 22(1)); for 2026 imports that first surrender and the accompanying declaration fall due by 30 September 2027. Where a carbon price has already been paid in the country of production, Article 9 allows a corresponding reduction in the number of certificates to be surrendered, provided it can be evidenced.

The operative text is Regulation (EU) 2023/956, materially amended by Regulation (EU) 2025/2083 of 8 October 2025, which simplified and strengthened the mechanism and introduced the 50-tonne threshold. Two implementing acts fill in the detail most relevant to importers: Commission Implementing Regulation (EU) 2025/486 of 17 March 2025 sets the conditions and procedures for obtaining authorised CBAM declarant status, and Commission Implementing Regulation (EU) 2025/2548 lays down the certificate-pricing methodology. This dossier is an information source, not legal advice: whether, and how, these obligations bite depends on the specific goods, volumes and country of origin involved, and the position should be confirmed with the relevant national competent authority.

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