EU CBAM
Carbon Border Adjustment Mechanism — Regulation (EU) 2023/956
Standard Introduction
The EU Carbon Border Adjustment Mechanism (CBAM) entered its definitive period on 1 January 2026, when embedded-emissions and carbon-cost obligations began accruing for covered imports. For goods other than electricity and hydrogen, the single mass-based threshold is initially 50 tonnes per importer per calendar year; Annex I CN codes and transaction roles still determine scope.
2026 is not the year in which certificates must already be bought and surrendered. Accredited verifiers began entering the Registry in September 2026, certificate purchases for 2026 imports begin in February 2027, and the first annual declaration and corresponding surrender are due by 30 September 2027.
2026 Emissions, 2027 Settlement
The definitive regime applies to covered imports from 1 January 2026, but certificates for those imports become purchasable from February 2027 and the first declaration and surrender are due by 30 September 2027.
Actual or Default Emissions
Declarants may use Commission default values or actual installation emissions. Actual values require verification by an accredited CBAM verifier.
Verification Is Now Operational
Accredited verifiers can register in the CBAM Registry from 1 September 2026, begin document review and site work, and issue the first verification reports from January 2027.
list_alt Definitive-Period Workstreams
- CN-code and 50-tonne threshold monitoring
- Authorised CBAM declarant status and customs controls
- Installation-level emissions monitoring for 2026 imports
- Choice between default values and actual verified emissions
- Accredited-verifier selection and Registry data exchange
- Quarter-specific 2026 certificate-price forecasting
- September 2027 declaration and surrender readiness
- Evidence reconciliation across customs, suppliers, emissions, and finance
Who Needs to Comply?
EU importers or indirect customs representatives importing covered cement, iron and steel, aluminium, fertilisers, electricity, hydrogen, and listed downstream goods. For goods other than electricity and hydrogen, the single mass-based exemption is initially 50 tonnes per importer per calendar year. Non-EU installation operators and accredited verifiers supply the emissions and assurance evidence used by authorised CBAM declarants.
Key Requirements
Control Scope and Authorisation
Map Annex I CN codes, electricity and hydrogen exceptions, cumulative net mass by importer, import roles, and authorised CBAM declarant status before customs clearance.
Capture 2026 Import and Emissions Data
Reconcile customs quantities and quarter of import with installation, production-route, precursor, direct and indirect emissions, and carbon-price-paid evidence.
Choose the Emissions Basis
Use the legally applicable Commission default values or obtain actual installation data calculated under the definitive methodology. Actual values must be independently verified.
Arrange Registry-Based Verification
When using actual values, engage an accredited verifier, connect the verifier and non-EU installation operator in the Registry, and resolve data gaps before the verifier issues its report.
Plan Declaration and Certificates
Forecast 2026 liability using the published quarterly prices, prepare to purchase certificates from February 2027, and submit the first declaration and surrender by 30 September 2027.
Implementation Roadmap
Confirm scope, threshold and authorisation
Map Annex I CN codes, importer and indirect-customs-representative roles, electricity and hydrogen exceptions, and cumulative net mass against the 50-tonne threshold. Confirm the authorised CBAM declarant or application reference used for customs clearance.
Build the 2026 emissions record
Reconcile each covered import to its quarter, quantity, origin, installation, production route, precursors, embedded emissions, and carbon price paid. Decide where Commission defaults are acceptable and where actual verified values create sufficient commercial value.
Prepare verification and Registry exchange
For actual emissions, contract an accredited verifier and connect the declarant, non-EU installation operator, and verifier through the CBAM Registry. Resolve monitoring-plan, calculation, evidence, site-visit, and misstatement issues before reports can be issued from January 2027.
Forecast, declare and surrender
Forecast 2026 liability using the quarterly prices assigned to each import quarter, prepare certificate purchasing from February 2027, and reconcile the first annual declaration and certificate surrender by 30 September 2027. Retain evidence for competent-authority review.
Compliance Checklist
checklist Scope, threshold and customs
checklist Emissions and verification
checklist Declaration and certificates
CBAM 2026 Activity Versus 2027 Settlement
The definitive period has started, but data, verification, certificate purchase, declaration, and surrender occur on different dates.
| Workstream | 2026 action | 2027 action | Primary owner |
|---|---|---|---|
| Import and authorisation | Use authorised declarant or application reference where required; monitor scope and threshold | Maintain authorisation and Registry data | Importer and customs |
| Emissions and verification | Monitor installation emissions; begin verifier review and site work | Verifier issues report from January for actual values | Non-EU operator and accredited verifier |
| Certificate cost | Apply published quarterly price to each import quarter for forecasting | Purchase from February and fund the liability | Finance and authorised declarant |
| Declaration and surrender | Build and reconcile the annual data set | Submit declaration and surrender by 30 September | Authorised CBAM declarant |
Common Misconceptions
CBAM certificates had to be purchased from January 2026.
The definitive period began in January 2026, but the Commission states that certificates for 2026 imports become purchasable from February 2027.
The first CBAM declaration is due in May 2027.
Regulation (EU) 2025/2083 moved the annual declaration and surrender deadline to 30 September, first applying in 2027 for 2026 imports.
Every importer below 50 tonnes is exempt from every CBAM sector.
The single mass-based exemption does not cover electricity or hydrogen, and the importer must still monitor cumulative mass and apply the exact CN-code rules.
Actual supplier data can be declared without independent verification.
Where a declarant chooses actual emissions rather than applicable defaults, the calculation must be verified by an accredited CBAM verifier.
Penalties & Enforcement
An authorised CBAM declarant that fails to surrender the required certificates by 30 September is liable for a penalty for each missing certificate, linked to the EU ETS excess-emissions penalty, while the surrender obligation remains. Importing covered goods without the required authorisation or improperly using the 50-tonne exemption can also trigger penalties and customs or authorisation consequences.
Frequently Asked Questions
When did the definitive CBAM period start?
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The definitive period applies to covered imports from 1 January 2026. Emissions and liability accrue for 2026 imports, while certificate purchases for those imports begin in February 2027 and the first declaration and surrender are due by 30 September 2027.
Who needs authorised CBAM declarant status?
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EU importers or indirect customs representatives importing covered goods generally need authorised CBAM declarant status. For goods other than electricity and hydrogen, the single mass-based exemption is initially 50 tonnes per importer per calendar year; the exact CN-code and role analysis still controls.
When can CBAM certificates be purchased?
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The Commission states that certificates covering 2026 imports can be purchased on the common central platform from February 2027. The published quarterly prices for 2026 are used for emissions in goods imported during the corresponding quarter.
When is the first CBAM declaration and surrender due?
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The first annual CBAM declaration, covering 2026 imports, and the corresponding certificate surrender are due by 30 September 2027.
Are actual verified emissions always required?
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No. A declarant may use applicable Commission default values or actual emissions. When actual emissions are used, they must be calculated under the definitive methodology and verified by an accredited CBAM verifier.
What changed for verifiers in September 2026?
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From 1 September 2026, accredited CBAM verifiers can request registration and access through the CBAM Registry. They can begin document review and site work in 2026, with the first verification reports expected to be issued from January 2027.
How should non-EU installation operators prepare?
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They should register through the third-country installation portal where useful, document monitoring boundaries and production routes, calculate emissions under the definitive rules, connect with importers and an accredited verifier, and resolve evidence or site-access gaps before verification.
Does the 50-tonne exemption remove all CBAM data needs?
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No. Importers need controls to monitor cumulative net mass and prevent threshold splitting or misclassification, and electricity and hydrogen are not covered by the single mass-based exemption. Customers may also request installation emissions data for their own CBAM obligations.
Official Documentation
Official PDF for EU CBAM
Official publication or summary for EU CBAM
Official online resource
European Union guidance and reference material
Implementation toolkit
Templates, guidance, or companion resources for EU CBAM