CBAM for importers, answered

The hard part of the carbon border adjustment is not the declaration — it is the purchasing. An importer who cannot get verified emissions data pays default values with a mark-up that rises every year. These are the questions that decide what CBAM costs you.

The basics — which goods are in scope, the 50-tonne exemption, when you pay — are answered on the home page. This page does not repeat them. Reference material, not legal advice.

Getting the data

What exactly do I need from my supplier? per consignment

The embedded emissions of the goods, attributed to what you actually imported: direct emissions from production, the relevant indirect emissions, the emissions of the precursors that went into it, and any carbon price already paid in the country of origin. Verified, and tied to the installation that made it.

What that means in a purchase conversation, in the order suppliers can answer it:

Which installation made this batch. Emissions are per installation, not per company. A supplier with three plants has three answers.
Direct emissions per tonne of product, on the methodology the regulation requires — not a corporate footprint number and not a product LCA, which are different things and will not be accepted.
Precursors. Steel made from imported pig iron carries the pig iron's emissions. This is where the number moves most, and where suppliers most often have a gap.
Carbon price already paid in the country of origin, with evidence, because it reduces what you surrender.
Verification by an accredited verifier.

Put this in the contract rather than the purchase order. Suppliers who have never reported emissions need months, not weeks, and the data has to arrive for every consignment — not once.

Common mistake: accepting a sustainability report or an ISO 14064 statement. Neither is the figure CBAM asks for, and swapping one for the other is discovered at declaration, when it is too late to go back to the supplier.

Source: Regulation (EU) 2023/956 and its implementing acts on the determination of embedded emissions and verification. Checked: 3 September 2026.

My supplier will not give emissions data. What then? you pay the mark-up

You fall back on default values, which are set per country of origin and per product and are deliberately conservative. On top of that comes a mark-up designed to make the fallback the expensive option: 10% in 2026, 20% in 2027 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen. For fertilisers it is 1% from 2026.

Read that as a price signal rather than a penalty, because that is how it is built: the default is always meant to cost more than the truth. Two consequences for an importer:

The gap widens. A supplier who cannot deliver data in 2026 costs you 10% over the default; the same supplier in 2028 costs 30% over it. The commercial case for switching supplier, or for helping this one measure, grows every year.
It is a negotiable cost. Once you can quantify the difference between the default and a plausible verified figure, it belongs in the price discussion. Suppliers who have the data will use it against those who do not.

The default values themselves are published and are revised: a correction with retroactive effect to 1 January was made in 2026, so check which version applies to the period you are declaring rather than the one you downloaded last year.

Common mistake: treating defaults as the easy route for the first year and planning to switch later. The mark-up rises on a fixed schedule while supplier onboarding takes months, so the year you decide to switch is the year you already paid for.

Source: Implementing Regulation (EU) 2025/2621 on default values, as corrected in 2026; mark-ups of 10% (2026), 20% (2027) and 30% (from 2028) for cement, iron and steel, aluminium and hydrogen, 1% from 2026 for fertilisers. Checked: 3 September 2026.

The threshold and the authorisation

How do I know whether I am over 50 tonnes? cumulative

Add up the net mass of every CBAM good you import in the calendar year, across all the categories together. It is per importer, not per product, per shipment or per supplier. Steel in January and aluminium in November count towards the same 50 tonnes.

The threshold replaced the old €150-per-consignment trigger, and it works differently in a way that catches people:

It is annual and running. Nobody warns you at 49 tonnes; you have to watch the total yourself.
It is one total. Four categories at fifteen tonnes each is sixty tonnes, not four times "under the threshold".
Under it you are out entirely — no reporting, no authorisation, no certificates. Not "lightly regulated".
The authorisation has to exist before you cross. Applying in the month you exceed it is already late.

Practically: put the CN codes of the CBAM goods on a running total in your own system, and set an internal alert well below 50 — 35 tonnes gives you the months an authorisation takes.

Source: Regulation (EU) 2023/956 as amended by the CBAM Omnibus Regulation (adopted 8 October 2025, in force 20 October 2025), introducing the 50-tonne mass-based de minimis. Checked: 3 September 2026.

How do I become an authorised declarant, and how long does it take? months

You apply to the competent authority in the member state where you are established, through the CBAM registry. It is not a form you file the week you need it: the authority assesses your establishment, your financial and operational capacity and your compliance record. Importers who filed by 31 March 2026 could keep importing while the decision was pending; filing later carries no such protection.

What to have ready before you start:

EORI number and establishment in the member state you apply in.
An estimate of your annual CBAM imports by category and value.
Who is responsible internally — the authorisation attaches to a person as well as a company.

Without the authorisation, CBAM goods above the threshold cannot lawfully be imported. That is the sanction that bites first: not a fine, but customs.

Common mistake: assuming your customs agent's authorisation covers you. The declarant is the importer of record; an agent acting in your name does not carry your authorisation.

Source: Regulation (EU) 2023/956, authorisation of CBAM declarants; transitional protection for applications filed by 31 March 2026. Checked: 3 September 2026.

What it costs, and when

What does a certificate cost, and when do I buy? from February 2027

Sales of CBAM certificates start in February 2027, for 2026 emissions. For 2026 the price follows the quarterly average of EU allowance auction prices; from 2027 it follows the weekly average. One certificate covers one tonne of embedded CO2.

The timing is the part to plan for, because obligation and payment are a year apart:

2026: collect the data. Nothing is bought and nothing is surrendered.
From February 2027: certificates for 2026 can be bought.
By 30 September 2027: the annual declaration for 2026 is due, with the certificates surrendered.
From 2027 onwards: a running obligation — by the end of each quarter you must hold certificates covering at least 50% of the embedded emissions accumulated so far that year.

That last point is the working-capital change. Up to and including 2026 the cost is deferred; from 2027 it becomes a quarterly cash requirement that moves with the allowance price. Budget it against the EUA price, not against a fixed figure.

Common mistake: pricing 2026 imports as if CBAM were free because nothing is paid that year. The liability accrues in 2026 and lands in 2027; a contract signed in 2026 without a CBAM clause carries it.

Source: Regulation (EU) 2023/956; certificate sales from February 2027 in respect of 2026, quarterly EUA average for 2026 and weekly thereafter; quarterly 50% holding requirement from 2027. Checked: 3 September 2026.

My product contains steel. Is it in scope? the CN code decides

Not because it contains steel — because of its CN code. CBAM lists specific customs codes, and a finished product made of a covered material is usually outside it while the material itself is inside. A steel screw and a washing machine containing steel are answered differently, and only the tariff classification gives the answer.

So the question "is my product CBAM" is really "what is my CN code, and is that code on the list". Two practical consequences:

Get the classification right first. It decides duty, CBAM and often more. A wrong code is the single most expensive mistake available in importing, and it is not a CBAM question.
Watch the scope, not just your product. The list of covered goods can be extended; downstream products have been discussed since the mechanism was designed. What is outside today is not permanently outside.

If your goods are not on the list, CBAM does not touch you at all — no report, no authorisation, nothing. That is worth confirming once, in writing, rather than assuming annually.

Source: Regulation (EU) 2023/956, Annex I (goods covered, by CN code). Checked: 3 September 2026.

Where to go next

Not sure whether CBAM is even the rule that applies to what you import? Six questions name every regime that lands on your situation, and the CBAM answer there tells you what the tonnage decides.

Importing steel or aluminium usually means other regimes too — see EPR for the packaging it arrives in and sanctions screening for the counterparty.