Since 1 January 2026, goods covered by Regulation (EU) 2023/956 (CBAM) may be imported only by an authorised CBAM declarant (Article 4), unless the importer stays within the single mass-based threshold of 50 tonnes net mass per calendar year (Article 2a and Annex VII); the threshold does not apply to electricity or hydrogen. Both rules apply from 1 January 2026 under Article 36(2), point (b), as amended by Regulation (EU) 2025/2083.
What changed
Regulation (EU) 2025/2083 (OJ L, 17 October 2025) amended Regulation (EU) 2023/956. Since 1 January 2026, Article 4 limits imports of CBAM goods to authorised CBAM declarants and Article 2a exempts an importer whose goods in the iron and steel, aluminium, fertiliser and cement sectors do not cumulatively exceed 50 tonnes net mass in a calendar year; Article 2a does not apply to electricity or hydrogen (Article 2a(4)). An importer or indirect customs representative that applied for the authorisation by 31 March 2026 may provisionally continue to import until the competent authority decides (Article 17(7a)). Member States sell CBAM certificates on a common central platform from 1 February 2027 (Article 20(1)), and the first CBAM declaration and surrender of certificates for the year 2026 are due by 30 September 2027 (Articles 6(1) and 22(1)).
Why it matters
An importer or indirect customs representative without the authorisation cannot import CBAM goods above the threshold. The first annual CBAM declaration and the first surrender of certificates, for goods imported in 2026, are due by 30 September 2027.
Who is affected
Importers of goods listed in Annex I to Regulation (EU) 2023/956 and indirect customs representatives acting for them; forwarders and customs brokers who lodge their declarations.
Rolescustoms teamscompliance teamsprocurement teams
Organisationsimportersindirect customs representativesforwarders and customs brokers
What to check next
- Add up your imports of CBAM goods per calendar year in net mass against the 50-tonne threshold (Article 2a); electricity and hydrogen fall outside it
- Confirm that you hold, or applied by 31 March 2026 for, the status of authorised CBAM declarant (Articles 4, 5 and 17(7a))
- Collect verified embedded-emissions data for goods imported in 2026
- Prepare the first CBAM declaration and the certificate surrender due by 30 September 2027 (Articles 6(1) and 22(1))
Key dates
- 2026-01-01Articles 2a and 4 apply (Article 36(2), point (b))
- 2026-03-31Application deadline for provisional import while the authorisation application is pending (Article 17(7a))
- 2027-02-01Sale of CBAM certificates starts (Article 20(1))
- 2027-09-30First CBAM declaration and surrender for 2026 (Articles 6(1) and 22(1))
Source. EUR-Lex — Regulation (EU) 2025/2083 ↗
Document: Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 — OJ L, 17.10.2025
Verified by Trusq against this source on 6 Nov 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.
Document: Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 — OJ L, 17.10.2025
Verified by Trusq against this source on 6 Nov 2026. Trusq publishes only what it can trace to an official source; the source text prevails. Not legal advice.