EU CBAM 2026 marks the start of the Carbon Border Adjustment Mechanism’s definitive period, which began on 1 January 2026 and replaced the 2023–2025 reporting-only phase. The Carbon Border Adjustment Mechanism (CBAM) is a carbon price the EU charges on imports of certain high-emission goods. From 2026, importers bringing in more than 50 tonnes a year of covered goods (cement, iron and steel, aluminium, fertilisers, plus hydrogen and electricity) must become an authorised CBAM declarant, report embedded emissions, and surrender CBAM certificates. Importers under the 50-tonne annual threshold are exempt, which the European Commission says covers about 90% of importers while still capturing roughly 99% of embedded emissions. The first certificate purchases start on 1 February 2027, and the first annual declaration is due on 30 September 2027 for 2026 imports. This is general information, not legal advice: verify against the official European Commission CBAM portal and your national customs authority.
Key takeaways: the short version for busy importers
- Most small importers are exempt. Under 50 tonnes a year of CBAM goods means no CBAM obligations, which covers about 90% of importers.
- The definitive (paying) period has been live since 1 January 2026; the 2023–2025 phase was reporting only.
- Six categories are covered: cement, iron and steel, aluminium, fertilisers, hydrogen, electricity.
- Watch two traps: cross 50 tonnes at any point in the year and the whole year’s imports fall in scope, and hydrogen and electricity are never exempt by volume.
- Key dates: certificate sales begin 1 February 2027; the first annual declaration and surrender are due 30 September 2027.
- Your freight forwarder or customs representative can hold the data, but the legal obligation can still rest with you as the importer.
What CBAM is and why it exists
The Carbon Border Adjustment Mechanism puts the same carbon cost on imported cement, steel, aluminium, fertilisers, hydrogen and electricity that EU producers already pay under the EU Emissions Trading System (EU ETS). The goal is to stop “carbon leakage”, the risk that production moves outside the EU to dodge climate rules. Embedded emissions, the greenhouse gases released while making a product, are what CBAM prices.
The two phases differ sharply. The transitional period (October 2023 to December 2025) was reporting only: importers declared embedded emissions but paid nothing. The definitive period started on 1 January 2026, and this is when financial obligations begin, per the European Commission (external, nofollow). For importers above the threshold, reporting now turns into real cost.
This guide is written for SME importers across the Balkans, the EU and CIS corridors who do not have a full compliance department. It covers who is in scope, which goods count, the deadlines, and what a freight forwarder can do. It is not tax or legal advice, and it leaves aside sector-specific edge cases and the deeper obligations of large industrial manufacturers.
Who is in scope in 2026
Here is the good news first: most small importers are exempt. The definitive period introduced a single mass-based de minimis threshold. Importers bringing in 50 tonnes or less per year (cumulative net mass) of CBAM goods are exempt from reporting, declaration and certificate-surrender duties, replacing the old €150-per-shipment trigger. The European Commission (external, nofollow) estimates this exempts about 90% of importers while still covering roughly 99% of embedded emissions, since the exempted businesses are mostly SMEs and individuals.
Who is in scope, then? Anyone bringing in more than 50 tonnes a year of covered goods faces the full obligations below.
Two catches deserve a clear flag. First, the threshold is cumulative across the calendar year: cross 50 tonnes at any point and every import that year, including the small early shipments, becomes subject to CBAM. Second, hydrogen and electricity are not covered by the de minimis exemption at all, so any volume of those two puts you in scope. On the Balkan and CIS lanes we handle, small importers most often get caught by this cumulative-tonnage rule, not the headline goods list: bring aluminium profiles in through several Less than Container Load (LCL) shipments and each pallet feels too small to count, yet the year-to-date total is what decides it.
Which goods CBAM covers
Six categories fall under CBAM, the materials with the highest embedded emissions rather than finished products:
- Cement
- Iron and steel
- Aluminium
- Fertilisers
- Electricity
- Hydrogen
The de minimis exemption does not apply evenly across them. Four categories qualify for the 50-tonne safety net: cement, fertilisers, iron and steel, and aluminium. Two do not: hydrogen and electricity stay in scope regardless of volume.
One practical point for most SME shippers: textiles, electronics, machinery, food and other consumer goods are generally not in scope. Check the exact HS code of your goods against the covered list rather than guessing from the product description, since classification is what decides whether an item counts.
What in-scope importers must actually do
Importers above 50 tonnes a year face three obligations, set out by the European Commission:
- Apply for authorised CBAM declarant status. Only an authorised declarant may import covered goods above the threshold.
- Declare embedded emissions annually for the goods you brought in over the year.
- Surrender CBAM certificates for those declared emissions, with one certificate broadly matching one tonne of CO₂.
Two further details matter in practice. From 1 January 2026, actual-emissions data must be verified by an accredited third-party verifier, so figures cannot be self-asserted. And the importer’s indirect customs representative, typically a freight forwarder or customs agent, may carry these duties on the importer’s behalf.
CBAM deadlines you can’t miss (2026–2027)
Every date below is taken exactly from the official EU timeline:
| Milestone | Date |
|---|---|
| Transitional period (reporting only) | Oct 2023 – Dec 2025 |
| Definitive period starts (financial obligations begin) | 1 January 2026 |
| Verified actual-emissions data required | from 1 January 2026 |
| CBAM certificate sales begin (postponed from 1 Jan 2026) | 1 February 2027 |
| First annual CBAM declaration + certificate surrender (for 2026 imports) | 30 September 2027 |
| Quarterly certificate holding requirement | 50% of embedded emissions since year start (down from 80%) |
The 1 February 2027 certificate-sales date and the 50-tonne de minimis are both confirmed in the ICAP (external, nofollow) summary of the simplification rules. In short, declarants buy certificates in 2027 for emissions from their 2026 imports. The quarterly holding requirement, the share of expected emissions a declarant must hold as the year runs, was also eased to 50% from the originally planned 80%.
How much CBAM certificates cost
There is no fixed CBAM tariff. One CBAM certificate broadly equals one tonne of embedded CO₂, and its price equals the EU ETS auction price per tonne: a quarterly average in 2026, moving to a weekly average from 2027. Compliance cost therefore tracks the live carbon market, not a published rate card.
The total bill also ramps up over the decade. The embedded-emissions calculation includes an adjustment for the phase-out of EU free allocation, which runs from 2026 to 2034, so the share an importer pays for rises year on year. Because the ETS price moves continuously, no honest guide can quote a fixed euro figure per tonne — treat any specific range you see as an estimate and check it against current ETS auction data.
Are you in scope? An SME decision framework
Most small importers are exempt — here is how to be sure. This is the “50-tonne scope check,” a four-question framework you can run in about a minute:
- Do you import any of the six covered goods? Cement, iron and steel, aluminium, fertilisers, hydrogen, or electricity. If you import none of these, CBAM does not apply to you, and you can stop here.
- Is it hydrogen or electricity? If yes, there is no de minimis safety net. You are in scope regardless of tonnage, so skip straight to step four.
- Will your cumulative net mass of covered goods stay at or below 50 tonnes across the whole calendar year? If yes, you are exempt. This is the roughly 90% case, and the trap lives here: cross 50 tonnes at any point and the whole year falls in scope. Track your cumulative tonnage year-to-date; do not judge it shipment by shipment.
- If you are over 50 tonnes, or you import hydrogen or electricity: you, or your indirect customs representative, need authorised CBAM declarant status, verified embedded-emissions data, and certificates to surrender.
For importers in scope, or who want to be ready, a short pre-import checklist keeps the obligations manageable:
- Track cumulative CBAM-goods tonnage year-to-date, not per shipment, so the 50-tonne line never surprises you.
- Collect supplier embedded-emissions data early, since verified figures take time to gather and must come from an accredited verifier.
- Confirm the HS codes of your goods against the covered list before booking, so classification doesn’t catch you out.
- Decide who holds declarant status: you directly, or your customs representative on your behalf, and record it in writing.
- Diarise 30 September 2027, the first annual declaration and surrender deadline for 2026 imports.
In our own experience, the part-load shippers are the ones who get surprised, so we flag the running tonnage on every consignment and warn the importer well before it nears 50 tonnes, not after.
What your freight forwarder / indirect customs representative does
The customs and mass data CBAM needs is data a forwarder already holds. When a freight forwarder or customs agent lodges your import declaration, it acts as your indirect customs representative, filing with customs on your behalf. That role means it already records the goods, their HS codes and their net mass, the exact figures CBAM reporting draws on. A forwarder can also help collate supplier embedded-emissions data and, where you agree, support or carry the declarant duties.
Honesty matters more than a sales pitch here. According to the European Commission, the indirect customs representative may carry CBAM duties, but the legal obligation can still rest with the importer. So the most useful step is to confirm in writing who the authorised CBAM declarant is (you or your representative) before goods move. That closes the common gap where each side assumes the other is handling it.
For the small importers we handle on Balkan and CIS lanes, we already lodge the customs declaration, so the mass data CBAM reporting depends on is in our records from day one. As an EU-registered forwarder based in Burgas focused on consolidated cargo, we see the cumulative-tonnage question most often with LCL shippers, where many small consignments quietly add up. We’re candid about the limits, too: a forwarder’s role is data and customs support, not a substitute for legal or tax advice. If you want help mapping your import flows, our consolidated cargo service is the place to start.
EU CBAM 2026: what to do next
Back to the question this guide opened with: are you in scope for EU CBAM 2026? For most SMEs the answer is no, because under 50 tonnes a year of covered goods means you are exempt. If you are over that line, or import hydrogen or electricity, line up authorised CBAM declarant status, verified emissions data and certificates well before the 30 September 2027 declaration. Run the 50-tonne scope check above, then talk to your freight forwarder about who holds the data.
This guide is general information current as of June 2026, and it is not legal or tax advice. CBAM rules are still being operationalised and have already shifted; the Omnibus simplification package was signed off by the Council of the EU (external, nofollow) on 29 September 2025, introducing the 50-tonne threshold and the revised dates. Always verify your position against the official European Commission CBAM portal and your national customs authority before acting. For a plain-language read on how CBAM touches your specific shipments, get in touch with our team — no obligation.
FAQ
What is the EU CBAM and what changed in 2026?
The EU Carbon Border Adjustment Mechanism is a carbon price on imports of certain high-emission goods. Its definitive period began on 1 January 2026, replacing the 2023–2025 reporting-only phase. From 2026, importers above the threshold must pay for the embedded emissions of covered goods, not just report them.
Who has to comply with CBAM in 2026, and am I exempt?
Importers bringing in more than 50 tonnes a year of covered goods must comply. Importers under 50 tonnes a year are exempt, which the European Commission says covers about 90% of importers. So most small importers have no CBAM obligations.
What is the 50-tonne CBAM threshold?
It is a single annual cumulative-mass threshold that replaced the old €150-per-shipment rule. If your covered-goods imports stay at or below 50 tonnes across the calendar year, you are exempt. Cross 50 tonnes at any point and all that year’s imports fall in scope, and hydrogen and electricity are never exempted by volume.
Which goods does CBAM cover?
CBAM covers six categories: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. These are high-emission raw and industrial materials. Most consumer goods, textiles, electronics, machinery and food are not directly in scope.
When are the CBAM deadlines?
Certificate sales begin on 1 February 2027, postponed from the originally planned 1 January 2026. The first annual CBAM declaration and certificate surrender are due on 30 September 2027, covering 2026 imports.
How much do CBAM certificates cost?
One certificate broadly equals one tonne of embedded CO₂, priced on the EU ETS auction price in euros per tonne, as a quarterly average in 2026. The exact cost depends on live ETS prices and the phase-out of EU free allocation from 2026 to 2034, so it cannot be quoted as a fixed figure. This is general information, not legal or tax advice.
What does my freight forwarder do for CBAM?
Acting as your indirect customs representative, a freight forwarder lodges your customs declaration and so already holds the customs and net-mass data CBAM reporting needs. It can also help gather supplier emissions data and, where agreed, support or carry declarant duties. The legal obligation can still rest with you as the importer, so confirm in writing who the authorised declarant is.
