CBAM for importers, answered

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.

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.

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.
• Electricity and hydrogen are outside the exemption entirely. The de minimis does not apply to them, so a single kilogram of imported hydrogen carries the full obligation.
• You have to claim it. The exemption is declared in the customs declaration; it is not applied to you silently because your tonnage happens to be low.
• Cross it and the whole year comes with you. Exceeding the threshold makes you subject to the obligations for all emissions embedded in all goods you imported that calendar year, not only the tonnes above 50.

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. The codes are listed and searchable further down this page.

The threshold itself is not frozen: by 30 April each year the Commission checks whether it still leaves no more than 1% of embedded emissions outside the mechanism, and may change it by delegated act for the following calendar year.

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.

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.

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.

Three things follow for anyone who was already in the system:

• The quarterly report is gone. From 2026 the obligation is an annual CBAM declaration, submitted the year after the imports, with certificates surrendered against it. Nothing is due quarterly except, from 2027, holding enough certificates.
• A missed transitional report is not erased by the new regime. The penalty for failing to submit a CBAM report during the transitional period, or for submitting an incorrect one that is not corrected, is imposed by the competent authority of the member state where you are established.
• Being a reporting declarant is not being an authorised declarant. They are different statuses under different articles. Filing transitional reports gave you no standing in the definitive regime; the authorisation is a separate application.