CBAM Explained: the plain-English guide

categoryThe six covered sectors

CBAM covers six sectors, defined by Combined Nomenclature (CN) codes listed in Annex I of the regulation. Coverage follows the CN code of the imported good itself, so a steel sheet is covered but a car body made of steel is not.

balanceThe 50-tonne exemption (and the two sectors it never covers)

The headline change from the 2025 Omnibus is a 50-tonne de minimis threshold. If your cumulative annual net mass of cement, iron & steel, aluminium and fertilisers is 50 tonnes or less, you are exempt from authorisation, reporting and surrender. This replaced the old €150-per-consignment rule and exempts roughly 90% of importers — mostly SMEs — while still capturing more than 99% of embedded emissions. European Commission

badgeWho can import: the authorised CBAM declarant

From 1 January 2026, only an authorised CBAM declarant may import CBAM goods above the threshold. That can be the EU-established importer itself, or an indirect customs representative acting on its behalf — and for importers based outside the EU, a representative is required. You apply through the CBAM Registry's Authorisation Management Module, you need a valid EORI number, and the National Competent Authority can take up to 120 days to assess the application. Read the full declarant guide.

hubThe CBAM Registry

The CBAM Registry is the central EU platform for the definitive regime, accessed through the EU Customs Trader Portal. It is where declarants are authorised, annual declarations are filed, and certificates are bought, held, surrendered and sold back. It supersedes the earlier transitional CBAM Registry used for quarterly reports. European Commission. More on the registry.

receipt_longCBAM certificates, the price, and the CBAM factor

CBAM certificates are the instruments you surrender to cover the embedded emissions of your goods. One certificate equals one tonne of CO₂e. Their price is the weighted average of EU ETS auction clearing prices: four quarterly prices in 2026, then weekly from 2027. The Q1 2026 price was €75.36/tCO₂e, published on 7 April 2026. European Commission

But you do not pay for all your emissions yet. The CBAM factor sets the share of embedded emissions you actually pay for, ramping up as free ETS allowances are withdrawn:

insightsEmbedded emissions: direct, indirect, actual vs default

The thing CBAM measures is embedded emissions: the greenhouse gases released in making the good. Direct emissions come from the production process itself; indirect emissions come from the electricity consumed. Indirect emissions are counted for cement and fertilisers; for iron & steel and aluminium the treatment is narrower, largely direct.

You can report emissions using actual values (verified, installation-specific data, usually cheaper) or fall back on the Commission's default values, which carry a conservative mark-up — reported as around 10% in 2026 rising toward 30% by 2028 for aluminium, cement and steel, and only about 1% for fertilisers. If a carbon price was already paid abroad, you can deduct it. See the default-values table.

verified_userVerification

Where you use actual values, the underlying data must be checked by an independent accredited verifier, accredited under EU rules much like ETS verification. Importers relying solely on default values are not subject to verification. Read the verification guide.

descriptionThe annual declaration and surrender

Once a year, the authorised declarant files a CBAM declaration through the registry, covering the previous calendar year: quantities per CN code, total embedded emissions, the certificates to surrender after the CBAM factor and any foreign carbon-price deduction, and verification reports where actual values were used. The deadline is 30 September of the following year — the first one, for 2026 imports, is due 30 September 2027. From 2027 a quarterly minimum holding also applies: you must hold certificates for at least 50% of accrued emissions at each quarter-end.

warningPenalties

Fail to surrender enough certificates by 30 September and you face an excess-emissions penalty of €100 per tonne of CO₂e (indexed to inflation, like the EU ETS penalty) for each missing certificate — and paying it does not cancel the obligation; you still owe the certificates. Importing above the 50-tonne threshold without authorisation triggers an enhanced penalty of three to five times the standard rate, reduced where the threshold was exceeded by no more than 10%.

compare_arrowsCBAM vs the EU ETS, in one line

The EU ETS prices carbon for installations inside the EU; CBAM prices the embedded carbon of imports so they face an equivalent cost. As CBAM phases in from 2026 to 2034, the free ETS allowances for those sectors phase out, so the two converge.

updateWhat changed in 2026 (the Omnibus)

The 2025 Omnibus simplification, Regulation (EU) 2025/2083, reshaped CBAM just before the definitive period began. The key changes:

• The 50-tonne de minimis replaced the €150-per-consignment exemption.
• The first declaration and surrender moved from 31 May to 30 September 2027, and the annual deadline is now permanently 30 September.
• Certificate sales were delayed to 1 February 2027 (rather than during 2026).
• The quarterly minimum holding was cut from 80% to 50%.
• Emissions calculation and default-value use were simplified, and declarants may now delegate filing to EU third parties while remaining liable.

See the live deadlines and status board for what is settled and what is still moving.