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Guide

CBAM: what the EU carbon border adjustment means for importers

Updated on 19 July 2026

The Carbon Border Adjustment Mechanism (CBAM) puts a carbon price on imports of emission-intensive goods into the EU. Since 1 January 2026 the definitive regime applies: importers of covered goods need an authorisation, must report embedded emissions, and pay for them through CBAM certificates.

Whether CBAM affects you is decided by the customs tariff number: the covered goods are defined by their CN codes. This guide explains scope, thresholds, deadlines, and costs, and includes a calculator for a first cost estimate.

Which goods does CBAM cover?

CBAM currently covers six emission-intensive product groups, defined by CN codes in Annex I of the CBAM Regulation:

  • Cement
  • Iron and steel, including many downstream products such as screws and structures
  • Aluminium and aluminium products
  • Fertilisers
  • Hydrogen
  • Electricity

Who is exempt? The 50 tonne threshold

The CBAM Omnibus Regulation, in force since October 2025, introduced a de minimis threshold: importers whose cumulative imports of covered goods stay at or below 50 tonnes net mass per calendar year are exempt from all CBAM obligations. Electricity and hydrogen do not fall under this mass threshold.

The threshold removes obligations for the vast majority of small importers while keeping around 99 percent of embedded emissions in scope. Companies near the threshold must monitor their cumulative imports: crossing 50 tonnes during the year triggers the full obligations.

Key deadlines in the definitive regime

The definitive regime phases in with these dates:

  • Since 1 January 2026: definitive regime applies; importing covered goods above the threshold requires the status of an authorised CBAM declarant
  • From 1 February 2027: sale of CBAM certificates starts; certificates for 2026 imports are bought retroactively
  • By 30 September 2027: first annual CBAM declaration for 2026 imports, with surrender of the corresponding certificates

How the certificate cost is calculated

The price of a CBAM certificate follows the weekly average auction price of EU ETS allowances, per tonne of CO2 equivalent. The payable amount is based on the embedded emissions of the imported goods, either actual values from the producer or default values.

During the phase-in, only a growing share of embedded emissions is chargeable, mirroring the phase-out of free allocation in the EU ETS: the CBAM factor starts low in 2026 and rises to 100 percent by 2034. A carbon price already paid in the country of origin can be deducted.

What importers should do now

A practical CBAM readiness sequence looks like this:

  • Classify your product list correctly: CBAM scope is determined by the CN code, so reliable customs tariff numbers come first
  • Check the 50 tonne threshold against your cumulative annual imports of covered goods
  • Apply for authorised CBAM declarant status if you are above the threshold
  • Collect emission data from your suppliers, or plan with default values
  • Budget the certificate cost for 2026 imports, payable from 2027

CBAM screening in Zolltarif-Finder

Zolltarif-Finder flags CBAM-affected codes automatically during classification: every classified item shows whether its customs tariff number falls under Annex I, alongside the other compliance regimes. That turns a product list into a CBAM exposure overview without a separate screening project.

CBAM cost calculator

Estimate the annual certificate cost for one product group. Defaults are editable assumptions.

Embedded emissions
190 t CO2e
Chargeable share
5 t CO2e
Estimated certificate cost
€356

Need more than an estimate? Zolltarif-Finder clients use the fully fledged CBAM calculator: official default emission values per CN code and origin country, EU benchmarks, official certificate prices, the 50 tonne threshold across all imports, and their own classified part lists.

Talk to us

Simplified estimate for orientation only. Actual obligations depend on installation-specific emission values, benchmarks, deductions for carbon prices paid abroad, and the weekly ETS average price. This is not legal or financial advice.

Frequently asked questions

Does CBAM apply to my imports?

Only if the customs tariff numbers of your goods are listed in Annex I of the CBAM Regulation (cement, iron and steel, aluminium, fertilisers, hydrogen, electricity) and your cumulative imports of covered goods exceed 50 tonnes net mass per year.

What does a CBAM certificate cost?

The certificate price follows the weekly average EU ETS auction price per tonne of CO2 equivalent. The total cost depends on the embedded emissions of the goods, the CBAM factor of the import year, and any carbon price already paid in the country of origin.

When do I have to buy CBAM certificates for 2026 imports?

Certificate sales start on 1 February 2027. Certificates for embedded emissions of 2026 imports are bought retroactively and surrendered with the first annual CBAM declaration, due by 30 September 2027.

What happens if I import covered goods without authorisation?

From 2026, importing covered goods above the threshold requires the status of an authorised CBAM declarant. Imports without authorisation can lead to penalties; transition rules ease the start for importers whose application is pending.

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