CBAM 2026: importer obligations, 50-tonne threshold, deadlines

Legal basis and phases

CBAM is established by Regulation (EU) 2023/956. The transitional period, in which importers only reported emissions, ran until the end of 2025. Regulation (EU) 2025/2083, published on 17 October 2025 and in force since 20 October 2025, simplified the rules ahead of the definitive period. Since 1 January 2026 CBAM has applied under its definitive regime, with full phase-in stretching to 2034, in parallel with the phase-out of free allocation in the EU Emissions Trading System.

Which goods are covered

CBAM covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The exact scope is set by CN codes in Annex I to the regulation, so whether your product is covered depends on its tariff classification, not its trade name. Annex I also includes certain articles, such as selected steel and aluminium products, not only raw materials. Classification is covered in HS and CN codes and tariff classification.

The 50-tonne threshold

Regulation 2025/2083 replaced the earlier low-value consignment exemption with a single mass-based threshold: 50 tonnes net per importer per calendar year, cumulative across CBAM goods. The obligations apply when the importer exceeds 50 tonnes a year (more than 50 tonnes); an importer at exactly 50 tonnes or less does not exceed the threshold and is exempt from CBAM obligations. The threshold does not apply to electricity and hydrogen.

In practice:

• count the total net mass of all CBAM goods imported in the year, not individual shipments,
• if you plan to grow imports, arrange authorisation in advance, because exceeding the threshold without authorisation exposes you to penalties.

Authorised CBAM declarant status

An importer bringing in more than 50 tonnes of CBAM goods, or its indirect customs representative, must obtain authorised CBAM declarant status. The application goes to the national competent authority through the CBAM Registry. The Commission indicated that applications had to be submitted before importing and at the latest by 31 March 2026, which allowed imports to continue while the application was processed. A company only now starting to import CBAM goods above the threshold must obtain the status before crossing it.

According to Access2Markets, customs declarations for CBAM goods carry additional CBAM data in a dedicated data group (12 04 000 000). Agree this with your customs broker; the clearance process is covered in EU customs clearance step by step.

The annual cycle

Emissions: actual data or default values

The number of certificates depends on the emissions embedded in the imported goods. The importer can report:

• actual data from the producer, which must be verified by an accredited verifier, or
• default values published by the Commission.

Default values are simpler but are usually less favourable than good actual data. The regulation also allows a carbon price effectively paid in the country of origin to be taken into account, reducing the number of certificates to surrender; this has to be documented.

What it means for your supplier relationships

CBAM puts the cost and the data obligation on the importer, but the data sit with the producer. In contracts with suppliers of CBAM goods, consider:

• an obligation to provide emissions data under the CBAM methodology and to allow verification of the installation,
• identification of the production installation, not just the trader,
• information on any carbon price paid in the country of origin, with evidence,
• cost allocation if data turn out to be unavailable and default values must be used.

When comparing quotes, the cost of certificates is part of the landed cost. Two steel offers at the same price can differ in total cost if one producer has verified low emissions and the other provides no data. Checking the counterparty itself is covered in how to verify a foreign supplier.

An authorised declarant may delegate submission of CBAM declarations to a third party established in the EU with an EORI number, but responsibility for compliance stays with the declarant.

In practice, a one-page emissions data sheet per installation, refreshed each reporting quarter, keeps supplier questionnaires from turning into an annual scramble.

Many importers also keep a CBAM tonnage watchlist that flags when cumulative imports of covered goods approach the annual 50-tonne threshold.

Planned extension to downstream products

On 17 December 2025 the Commission proposed extending CBAM to 180 downstream products with a high steel or aluminium content, and strengthening anti-circumvention rules. The Council agreed its position on 12 June 2026, widening the list to around 200 goods. The European Parliament was due to adopt its position at the September 2026 plenary; trade press reported that it did so on 15 September, with an even wider scope. Trilogue negotiations come next, and at the time of publication the legislation had not been finally adopted. If you import machinery, parts or structures made of steel and aluminium, follow this process, because scope and dates may change.

Checklist

1. Check the CN codes of all imported goods against Annex I.
2. Calculate your annual net mass of CBAM goods and compare it with the 50-tonne threshold.
3. If you exceed the threshold, obtain authorised declarant status before importing.
4. Collect emissions data from suppliers, or prepare to use default values.
5. Budget for 2026 certificates, which are bought from February 2027.
6. Prepare the 2026 declaration by 30 September 2027.

Hiram does not calculate emissions or handle CBAM, but in negotiations you can record in successive versions of the terms who supplies emissions data and on what basis. If you are looking for a supplier of steel, aluminium or fertilisers, browse the market.

Sources

• European Commission: Carbon Border Adjustment Mechanism (opens in a new tab)
• European Commission: CBAM definitive regime (opens in a new tab)
• Access2Markets: Start of the definitive period of the CBAM in the EU (opens in a new tab)
• European Commission: Commission welcomes Council agreement on strengthening CBAM (12.06.2026) (opens in a new tab)
• European Parliament, EPRS: CBAM extension to downstream products (opens in a new tab)
• European Parliament, EPRS: Extension of CBAM scope to downstream goods and anti-circumvention measures (opens in a new tab)
• SteelOrbis: European Parliament backs CBAM extension to cover downstream steel products (opens in a new tab)
• ICAP: EU adopts simplifications of CBAM rules ahead of the compliance phase starting in 2026 (opens in a new tab)
• Reed Smith: What you need to know as CBAM simplification comes into effect (opens in a new tab)