What CBAM Requires of EU Importers in Six Sectors Since 1 January 2026

The European Union's Carbon Border Adjustment Mechanism, or CBAM, entered its definitive regime on 1 January 2026. The European Commission says it applies to imports of selected goods in six carbon-intensive sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The Commission describes CBAM as a way to make the price of imports reflect their embedded carbon emissions. It complements the EU Emissions Trading System, or EU ETS, and encourages cleaner industrial production in non-EU countries.

For importers, the change is concrete. They must apply for authorised CBAM declarant status when they bring in covered goods above a set threshold, report the emissions embedded in those imports each year, and buy and surrender certificates to match. The Commission places these obligations on EU importers. Embedded emissions are the emissions created in making the goods.

A Transitional Phase Gave Way to the Definitive Regime

CBAM ran in a transitional phase from 2023 to 2025. The Commission says the mechanism follows the gradual phase-out of free EU ETS allowances. Implementing Regulation (EU) 2023/1773 governs that transitional phase, and historical information about it is kept in a Commission archive.

The definitive regime started on 1 January 2026. From that date, importers face authorisation requirements and reporting obligations, and they must purchase and surrender certificates that match the embedded emissions of imported goods.

The legal base is Regulation (EU) 2023/956, which established the CBAM. Regulation (EU) 2025/2083 simplifies and strengthens it, according to the Commission. A consolidated text of 2023/956 that incorporates Regulation (EU) 2025/2083 is listed by the Commission.

Implementing acts fill in the detail. More than a dozen cover matters such as authorisation, emissions methods, certificate prices, the CBAM registry and information from customs authorities.

Who Must Apply for Authorisation, and the 50-Tonne Threshold

The Commission says EU importers, or their indirect customs representatives, must apply for authorised CBAM declarant status if they import more than 50 tonnes of CBAM goods. The Commission describes this as a single mass-based threshold for CBAM goods.

Importers are encouraged to follow the instructions in the Authorisation Management Module section and submit their applications now. Status rules are set in Implementing Regulation (EU) 2025/486, with a correcting act, 2025/2549.

Access to the CBAM Registry is requested through the national competent authority of the EU country where the importer is established. The declarant portal is accessed through the UUM&DS system, and the list of national competent authorities is dated 26 June 2026.

Customs authorities also have a defined role. Implementing Regulation (EU) 2025/2619 sets out the information they pass on under the regime.

How Embedded Emissions Are Declared and Checked

Each year, authorised declarants report the emissions embedded in their imports. The Commission says that where an importer can prove a carbon price was already paid during production, that amount can be deducted.

The calculation method is set out in Implementing Regulation (EU) 2025/2547. Default values are set in Implementing Regulation (EU) 2025/2621. Benchmarks for the definitive period are set out in 2025/2620, with an information-only Excel file dated 13 February 2026.

A corrected default-values file, published for information only, is dated 10 August 2026. Implementing Regulation (EU) 2026/1740 corrects the default values, with an update in July 2026.

Verification is carried out by accredited verifiers under Delegated Regulation (EU) 2025/2551, and Implementing Regulation (EU) 2025/2546 sets out the verification principles. The Commission's guidance for verifiers and national accreditation bodies is dated 24 August 2026.

Buying and Surrendering Certificates at EU Carbon Prices

Authorised declarants buy CBAM certificates from the national competent authority in their EU country of establishment. The Commission says the certificate price is based on the auction price of EU ETS allowances, expressed in euros per tonne of CO2. Prices are published each calendar quarter.

The averaging period changes over time. In 2026 the price is a quarterly average, and from 2027 it becomes a weekly average. Implementing Regulation (EU) 2025/2548 covers how those prices are calculated and published.

The CBAM Registry supports the submission of declarations, the management of certificates and the monitoring of compliance by competent authorities. The registry rules sit in Implementing Regulation (EU) 2024/3210, as amended by Implementing Regulation (EU) 2025/2550.

Importers then surrender the number of certificates that matches their declared embedded emissions each year. Implementing Regulation (EU) 2025/2620 covers the free allocation adjustment to the number of certificates to surrender.

Readers should check the regulations before any filing.

What US Exporters of Steel, Aluminium and Fertiliser Face

The Commission places the core duties on importers: authorisation, reporting, and certificate purchase and surrender.

For producers outside the EU, the Commission lists Guidance Nos. 1 to 5f for non-EU installation operators, dated 14 August 2026. The set covers CBAM concepts, a quick guide, emissions methods, free allocation adjustment, and sector guidance for fertilisers, iron and steel, aluminium, cement, hydrogen and electricity. More language versions are described as coming soon.

The Commission's guidance for importers of goods into the EU is dated 30 May 2024 and is available in several languages. The EU also offers guidance and technical support to developing countries and Least Developed Countries for greening industry and implementing CBAM, and a document on that support is dated 29 May 2024.

A synopsis report from the call for evidence launched on 28 August 2025 summarises stakeholder input on an implementing act for carbon prices paid in third countries during the definitive phase.

Proposals That Could Change the Scope

A proposal listed as COM(2025) 989 would extend CBAM to downstream goods and add anti-circumvention measures. Its supporting impact assessment is SWD(2025) 998.

The Commission also lists a report on the application of the CBAM Regulation. The call for evidence launched on 28 August 2025 is linked to three synopsis reports, on the free allocation adjustment, the CBAM methodology and carbon prices paid in third countries.

A separate proposal, COM(2025) 990, would establish a Temporary Decarbonisation Fund.