EU CBAM in 2026: The Definitive Period, the 50-Tonne Threshold and Key Dates
In brief
- The EU Carbon Border Adjustment Mechanism (CBAM) moved from reporting only to its definitive period on 1 January 2026. Importers will pay for the embedded emissions in goods imported from 2026.
- It covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, plus some products made from them.
- Importers bringing in 50 tonnes or less of CBAM goods a year (excluding electricity and hydrogen) are exempt. Above that, you need authorised CBAM declarant status.
- CBAM certificates go on sale from 1 February 2027. The first annual declaration, for 2026 imports, is due by 30 September 2027.
From 2023 to 2025, CBAM only meant filling in quarterly reports. From 2026 it costs money. The simplification adopted in 2025 removed most small importers, but those still covered now face a real bill and real deadlines. This guide is for EU importers, and for UK and other non-EU producers whose EU customers now need their emissions data.
Which goods are covered?
| Sector | Examples |
|---|---|
| Iron and steel | Sheets, bars, tubes, screws, bolts and some other articles of steel |
| Aluminium | Unwrought aluminium, bars, foil, tubes and some structures |
| Cement | Clinker and cement |
| Fertilisers | Nitrogen fertilisers, ammonia, nitric acid |
| Hydrogen | Hydrogen |
| Electricity | Imported electricity |
Coverage follows customs codes (CN codes), so check each product’s code against the CBAM annex rather than its description.
The 50-tonne threshold
The 2025 simplification regulation, (EU) 2025/2083, replaced the old €150-per-shipment exemption with a yearly threshold: if your combined imports of CBAM goods are 50 tonnes or less in a calendar year, you are exempt. The Commission says this removes most importers while keeping about 99% of embedded emissions covered. The threshold does not apply to electricity or hydrogen. If you go over 50 tonnes during the year, all your CBAM imports for that year are covered, so importers near the limit should track volumes month by month.
Key dates
| Date | What happens |
|---|---|
| 1 January 2026 | Definitive period begins; imports above the threshold need an authorised CBAM declarant |
| 1 February 2027 | CBAM certificates go on sale through the central EU platform |
| 30 September 2027 | First annual CBAM declaration due, covering 2026 imports, with verified emissions; certificates surrendered |
| 2026 to 2034 | CBAM charges phase in as free EU ETS allowances for the same sectors phase out |
The certificate price follows the EU Emissions Trading System. For 2026 imports, it is based on quarterly averages of EU ETS auction prices. A carbon price already paid in the country of production can be deducted.
What exporters outside the EU need to do
The legal duty falls on the EU importer, but the importer needs the actual embedded emissions of each product, verified, from the installation that made it. Without that data, the importer must use default values, which are set to be unfavourable and usually make the goods more expensive. For a UK, Turkish or Indian steel or aluminium producer, being able to provide verified installation-level emissions is becoming a condition for staying competitive in the EU market. The UK is also introducing its own CBAM from 2027: see UK CBAM explained.
Under CBAM, the customer who cannot get your emissions data pays the default value. That makes your data part of your price.
Installation-level emissions follow the same principles as a company footprint. Our GHG accounting service prepares the calculations and documentation for producers.
Frequently asked questions
When does the CBAM definitive period start?
On 1 January 2026. Imports from that date are subject to the financial obligation, with the first declaration due by 30 September 2027.
Who is exempt from CBAM?
Importers whose combined CBAM goods are 50 tonnes or less in a calendar year. The threshold does not apply to electricity or hydrogen.
When can CBAM certificates be bought?
From 1 February 2027, through the central EU platform.
Does CBAM apply to UK exporters?
The obligation is on the EU importer, but UK producers are asked for verified emissions data. The UK is introducing its own CBAM on 1 January 2027.
What happens without actual emissions data?
The importer must use default values, which usually lead to a higher CBAM cost.
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