What CBAM Changes for Your Imports in 2026
The figure may seem reassuring: 90% of European importers are exempt from the Carbon Border Adjustment Mechanism. But the remaining 10% account for 99% of CO2 emissions imported into the European Union. If your business imports steel, aluminium, cement or fertilisers, CBAM directly concerns you. Since 1 January 2026, the mechanism has entered its definitive phase — obligations are no longer limited to quarterly reports: you must now hold certificates, calculate embedded emissions in your goods, and anticipate a surcharge on top of your standard customs duties.
What is CBAM and Why Did the EU Introduce It?
CBAM, the Carbon Border Adjustment Mechanism, is a European regulatory instrument created by Regulation (EU) 2023/956 of 10 May 2023. It subjects goods imported into the EU to carbon pricing equivalent to that paid by European industry under the Emissions Trading System (ETS). The objective is to combat "carbon leakage": without this mechanism, a European company subject to carbon pricing would be disadvantaged against a competitor based in a country with no climate constraints. CBAM restores the balance by applying the same carbon price to imports. This mechanism is part of the European Green Deal and the "Fit for 55" package, aiming to reduce EU greenhouse gas emissions by 55% by 2030.
Which Products and Businesses Are Concerned?
CBAM targets specific sectors. Annex 1 of Regulation 2023/956 covers six categories: iron and steel, aluminium, cement, nitrogen fertilisers, electricity and hydrogen. The mechanism also applies to processed products containing these materials. If your cumulative imports of CBAM goods do not exceed 50 net tonnes per calendar year, you are exempt. Above this threshold, you must obtain authorised CBAM declarant status from the DGEC, which assigns you a mandatory CBAM account number for your customs declarations.
The CBAM Timeline
From 1 October 2023 to 31 December 2025, importers filed quarterly emissions reports with no financial obligation. Since 1 January 2026, CBAM is in its definitive phase with real financial obligations. Key dates: CBAM certificate purchases begin on 1 February 2027. The first annual declaration is due by 30 September 2027. Each quarter-end, importers must hold certificates covering at least 50% of emissions imported since the start of the year.
How Do CBAM Certificates Work?
Each certificate represents one tonne of CO2 equivalent. Prices are based on the weekly average ETS market price, recently around €70–80 per tonne. The preferred method uses actual data from the foreign producer verified by an accredited body. When unavailable, importers may use default values, subject to a progressive mark-up: 10% in 2026, 20% in 2027, 30% from 2028. A practical example: 500 tonnes of steel with an emission factor of 1.8 tCO2/tonne means covering 900 tonnes of CO2 — at €75/certificate, that is €67,500 per year.
Steps to Achieve Compliance
Apply for authorised CBAM declarant status with the DGEC, collect emissions data from foreign suppliers, integrate your CBAM account number into every relevant import declaration, and set up quarterly certificate stock monitoring. Non-compliance exposes you to fines of €300–500 per missing certificate, potential customs detention, and risk of losing your declarant status.
How Customeo Supports CBAM Compliance
Customeo integrates CBAM requirements natively into its digitalised clearance process. Declarants provide permanent regulatory monitoring, verify goods eligibility by cross-referencing tariff classification with Annex 1, and ensure the CBAM account number is correctly entered in each declaration. Customeo offers a single point of contact covering both standard customs compliance and CBAM obligations.
Frequently Asked Questions about CBAM
Does CBAM replace standard customs duties?
No. CBAM is a separate mechanism added on top of customs duties, import VAT and other existing taxes. CBAM certificates represent an additional charge linked to the carbon emissions embedded in imported goods.
What happens if I do not comply with CBAM?
The absence of authorised CBAM declarant status legally prevents importing goods covered by the regulation. For missing certificates, the fine is €300 to €500 per certificate. An incorrect customs declaration may be classified as a customs offence, with fines up to twice the value of the goods.
Must my foreign supplier provide emissions data?
The regulation does not directly impose an obligation on the foreign supplier. It is the importer who must collect this data. If unavailable, you may use default values, increased by a progressive mark-up.
Does CBAM apply to finished products containing steel or aluminium?
The current scope covers raw materials and certain semi-finished products listed in Annex 1. Complex finished products are not currently in scope, but the Commission has the ability to expand the scope in coming years.
