CBAM Glossary
Every CBAM term, in plain English
The Carbon Border Adjustment Mechanism comes with its own vocabulary: certificates, authorised declarants, embedded emissions, default values, the CBAM factor, surrender. Here is each term explained simply first, then with the precise legal phrasing, so you can read any CBAM document without a law degree. Every definition is grounded in the regulation itself.
Need the bigger picture first? Read what CBAM is, or check whether you are in scope.
37 of 37 terms
- A
Accredited verifier#
An independent body, accredited under EU rules, that checks your actual emissions data before you rely on it in a declaration. You only need a verifier if you use actual values, not if you rely solely on default values.
An independent verifier accredited by a national accreditation body under EU rules (similar to ETS verification). Verifies actual embedded-emissions data, monitoring methodology, system boundaries and foreign-carbon-price claims. Required only where actual values are used.
See also: Actual values, CBAM declaration, Carbon price paid abroad
Actual values#
Real, installation-specific emissions data, verified by an accredited verifier. Usually cheaper than default values, because defaults carry a conservative mark-up, but you need supplier data and verification to use them.
Verified, installation-specific embedded-emissions data, the preferred basis for the CBAM declaration. Their use triggers a verification requirement by an accredited verifier.
See also: Default values, Accredited verifier, Embedded emissions
Annex I goods#
The list of CBAM-covered products, set out by CN code in Annex I of the regulation. It spans six sectors: cement, iron & steel, aluminium, fertilisers, electricity and hydrogen, plus some downstream items like steel fasteners and pipe fittings.
The goods listed by CN code in Annex I to Regulation (EU) 2023/956, covering cement, iron & steel, aluminium, fertilisers, electricity and hydrogen, including certain semi-finished and downstream products (e.g. fasteners, pipe fittings) to prevent circumvention.
See also: CN code, CBAM, De minimis / 50-tonne threshold
Authorisation Management Module (AMM)#
The part of the CBAM Registry where you apply to become an authorised CBAM declarant. Applications opened on 31 March 2025.
The Authorisation Management Module within the CBAM Registry, used to apply for and manage authorised CBAM declarant status. Accessed through the EU Customs Trader Portal; applications opened 31 March 2025.
See also: CBAM Registry, Authorised CBAM declarant, National Competent Authority (NCA)
- C
Carbon leakage#
When production (and its emissions) shifts from the EU to countries with weaker carbon pricing, or EU goods are displaced by more carbon-intensive imports. CBAM exists to stop this.
The relocation of production or emissions to jurisdictions with lower carbon costs, or the substitution of EU output by more carbon-intensive imports. CBAM equalises the carbon cost between domestic and imported goods to prevent it.
See also: CBAM, EU ETS, Free-allowance phase-out
Carbon price paid abroad#
A carbon cost already paid in the country where the goods were made, for example a domestic carbon tax or ETS. You can deduct it from your CBAM bill, reducing the certificates you need to surrender, if you can substantiate the claim.
A carbon price effectively paid in the country of origin, deductible from the CBAM obligation. The claim must be substantiated and, where required, verified, and is adjusted for any rebates or compensation received abroad.
See also: Surrender, Accredited verifier, CBAM declaration
CBAM#
The Carbon Border Adjustment Mechanism: the EU rule that puts a carbon price on imports of certain carbon-intensive goods, so they face a cost similar to the one EU producers pay for their emissions. In effect, a carbon tariff at the border.
The Carbon Border Adjustment Mechanism established by Regulation (EU) 2023/956. It prices the embedded emissions of imported goods to mirror the carbon cost borne by EU producers under the EU Emissions Trading System (EU ETS).
See also: Regulation (EU) 2023/956, EU ETS, Carbon leakage, Embedded emissions, CBAM certificate
CBAM certificate#
The financial instrument an importer buys and then hands back ("surrenders") to cover the embedded emissions of its goods. One certificate equals one tonne of CO₂e. Its price tracks the EU ETS auction price.
A certificate corresponding to one tonne of CO₂e of embedded emissions, purchased from and sold back to Member States via the common central platform. Not tradable between operators and not equivalent to an ETS allowance. Q1 2026 price: €75.36/tCO₂e.
See also: Surrender, Common central platform, EU ETS, Quarterly minimum holding, Sell-back / repurchase
CBAM declaration#
The annual filing the authorised declarant makes through the CBAM Registry, reporting the goods imported, their embedded emissions, and the certificates to surrender. It is due 30 September of the year after import. The first one (2026 data) is due 30 September 2027.
The annual CBAM declaration filed via the CBAM Registry covering the previous calendar year. Due 30 September of the following year (moved from 31 May by the Omnibus). Contains quantities per CN code, total embedded emissions, certificates to surrender after the CBAM factor and any foreign carbon-price deduction, and verification reports where actual values are used.
See also: Authorised CBAM declarant, Surrender, CBAM factor (phase-in factor), Accredited verifier, Definitive period
CBAM factor (phase-in factor)#
The share of embedded emissions you actually pay for each year. It ramps up from 2.5% in 2026 to 100% in 2034, mirroring the phase-out of free EU ETS allowances. So in 2026 the real cost is small even though the regime is "definitive".
The proportion of embedded emissions subject to the CBAM obligation in a given year, rising from 2.5% (2026) to 100% (2034) in step with the free-allowance phase-out. Figures for 2030 onward are widely cited but worth confirming against the consolidated ETS Directive.
See also: Free-allowance phase-out, EU ETS, Surrender
CBAM Registry#
The central EU online platform for the definitive period. It is where declarants are authorised, annual declarations are filed, and certificates are bought, held, surrendered and sold back. Access is via the EU Customs Trader Portal.
The central EU IT platform for the definitive CBAM regime, accessed through the EU Customs Trader Portal (single sign-on via national customs identity systems). Includes the Authorisation Management Module. Supersedes the transitional CBAM Registry used for quarterly reports.
See also: Transitional CBAM Registry, Authorisation Management Module (AMM), Authorised CBAM declarant, CBAM declaration
CN code#
The customs classification code for a product. CBAM uses these codes to define exactly which goods are in scope, so you check your product's CN code against Annex I to confirm whether CBAM applies.
Combined Nomenclature customs code. Annex I to Regulation (EU) 2023/956 lists the in-scope goods by CN code. Coverage follows the CN code of the imported good itself.
See also: Annex I goods, CBAM
Common central platform#
The single EU venue where CBAM certificates are bought and sold back. Certificates are not traded between companies — only bought from, and sold back to, the authority here. Sales begin 1 February 2027.
The common central platform on which CBAM certificates are sold to and repurchased from authorised declarants. Sales of certificates for 2026 imports begin 1 February 2027.
See also: CBAM certificate, Sell-back / repurchase, CBAM Registry
- D
De minimis / 50-tonne threshold#
The headline Omnibus exemption: if your total annual imports of cement, steel, aluminium and fertilisers come to 50 tonnes or less, you are exempt from authorisation, reporting and surrender. It replaced the old €150-per-shipment rule. It does NOT apply to electricity or hydrogen.
A cumulative annual net-mass exemption of 50 tonnes (introduced by Regulation (EU) 2025/2083, replacing the €150-per-consignment rule). Cumulative across iron & steel, aluminium, fertilisers and cement; does not apply to electricity or hydrogen. Exempts ~90% of importers while still capturing >99% of embedded emissions. The Commission may adjust it annually.
See also: Authorised CBAM declarant, Annex I goods, Regulation (EU) 2025/2083 (the Omnibus)
Default values#
Fallback emissions figures published by the Commission per good and country of origin, used when you do not have actual, supplier-specific data. They are deliberately conservative, so they are usually more expensive than actual values.
Commission-published default emissions factors per CN code and country of origin (direct, indirect and total), used as a fallback where actual data is unavailable. Finalised for the definitive period in Implementing Regulations (EU) 2025/2620 (benchmarks) and 2025/2621 (default values).
See also: Actual values, Default-value mark-up, Embedded emissions
Default-value mark-up#
A conservative add-on applied to default values to discourage their use over real data. Reported as rising from around 10% in 2026 toward 30% by 2028 for aluminium, cement and steel, and only about 1% for fertilisers.
A conservative percentage added to default values in the definitive period (widely reported as ~10% in 2026 rising toward ~30% by 2028 for aluminium, cement and iron & steel; ~1% for fertilisers). Exact schedule is set by the implementing regulation on default values and should be confirmed against the latest act.
See also: Default values, Actual values
Definitive period#
The full CBAM regime, live since 1 January 2026. Now there are financial obligations, certificates, authorisation and verified data — not just reporting.
The CBAM compliance phase from 1 January 2026, with financial obligations, CBAM certificates, mandatory authorisation and verified emissions data. Replaces the transitional reporting-only phase.
See also: Transitional period, CBAM certificate, Authorised CBAM declarant, CBAM declaration
Direct emissions#
Emissions released by the production process itself, such as burning fuel or chemical reactions at the plant.
Emissions from the production processes of goods, including emissions from the production of heat and cooling consumed during production, regardless of where that heat or cooling is produced.
See also: Indirect emissions, Embedded emissions
- E
Embedded emissions#
The greenhouse gas emissions released in making an imported good. This is what CBAM measures and prices.
The greenhouse gas emissions released during the production of CBAM goods (and, for some, relevant precursors), expressed in tonnes of CO₂e. Comprises direct emissions and, where relevant, indirect emissions.
See also: Direct emissions, Indirect emissions, Actual values, Default values, CBAM declaration
EORI number#
The customs ID number EU traders use. You need a valid EORI number before you can apply to become an authorised CBAM declarant.
The Economic Operators Registration and Identification number, a prerequisite for applying for authorised CBAM declarant status and for delegating declaration filing.
See also: Authorised CBAM declarant, Indirect customs representative
EU ETS#
The EU Emissions Trading System: the EU's cap-and-trade scheme that puts a price on carbon for installations inside the EU. CBAM mirrors it at the border so imports face an equivalent cost.
The EU Emissions Trading System, the EU's cap-and-trade carbon market. The CBAM certificate price tracks the weighted average of EU ETS auction clearing prices, and free ETS allowances for CBAM sectors phase out as CBAM phases in.
See also: CBAM, Free-allowance phase-out, CBAM certificate, CBAM factor (phase-in factor)
Excess-emissions penalty#
The fine for failing to surrender enough certificates: €100 per tonne of CO₂e (rising with inflation, like the ETS penalty). Paying it does not cancel the obligation — you still owe the missing certificates.
A penalty identical to the EU ETS excess-emissions penalty — €100 per tonne CO₂e, indexed to inflation — for each unsurrendered certificate. Payment does not extinguish the surrender obligation. Importing above the threshold without authorisation triggers an enhanced penalty of 3×–5× the standard rate (reduced where exceeded by ≤10%).
See also: Surrender, National Competent Authority (NCA), De minimis / 50-tonne threshold
- F
Fit for 55#
The EU's package of climate laws aiming to cut net emissions by 55% by 2030. CBAM is one part of it.
The EU legislative package supporting a 55% net greenhouse gas reduction by 2030 and climate neutrality by 2050. CBAM is a component, alongside the strengthened EU ETS.
Free-allowance phase-out#
The gradual removal of the free EU ETS allowances that CBAM-sector producers in the EU have historically received. As the free allowances go, the CBAM obligation on imports rises to match — you cannot have both, or it would be double protection.
The withdrawal of free EU ETS allowances for CBAM sectors over 2026–2034, mirrored by the rising CBAM factor. Designed to avoid double protection of EU producers and maintain WTO compatibility.
See also: CBAM factor (phase-in factor), EU ETS, Carbon leakage
- I
Indirect customs representative#
An EU-established agent who can act as the authorised CBAM declarant for an importer, and must do so for importers based outside the EU. They take on the same obligations and penalties.
An EU-established customs representative who can be (and, for non-EU importers, must be) the authorised CBAM declarant, assuming the same obligations and liabilities. Authorised declarants may also delegate filing to EU-established third parties with an EORI, while remaining legally responsible.
See also: Authorised CBAM declarant, EORI number
Indirect emissions#
Emissions from the electricity used to make the good, generated elsewhere. CBAM counts these for cement and fertilisers; for steel and aluminium the treatment is narrower (largely direct).
Emissions from the generation of electricity consumed during the production of goods. Counted for cement and fertilisers; treatment for iron & steel and aluminium is largely limited to direct emissions during the phase-in.
See also: Direct emissions, Embedded emissions
- N
National Competent Authority (NCA)#
The body in each EU country that authorises CBAM declarants and enforces CBAM. It reviews your authorisation application (up to 120 days) and can impose penalties.
The Member-State authority designated to authorise CBAM declarants, enforce CBAM and apply penalties. Reviews authorisation applications (assessment period 120 days), consulting the Commission and other NCAs as needed. The list is published on the DG TAXUD CBAM website.
See also: Authorised CBAM declarant, Authorisation Management Module (AMM), Excess-emissions penalty
- O
Omnibus simplification#
The 2025 package of changes that made CBAM simpler and lighter — most notably the 50-tonne exemption. It was enacted as Regulation (EU) 2025/2083.
The 2025 "Omnibus" simplification package reducing CBAM administrative burden, enacted for CBAM as Regulation (EU) 2025/2083 (in force 20 October 2025). Introduced the 50-tonne de minimis, moved the declaration deadline to 30 September, delayed certificate sales to February 2027, and cut quarterly holding to 50%.
See also: Regulation (EU) 2025/2083 (the Omnibus), De minimis / 50-tonne threshold, CBAM declaration, Quarterly minimum holding
- Q
Quarterly minimum holding#
From 2027, a rule that you must hold enough certificates to cover at least half of the emissions you have built up so far that year, checked at the end of each quarter (31 Mar, 30 Jun, 30 Sep, 31 Dec).
The duty, from 2027, to hold CBAM certificates covering at least 50% of embedded emissions accrued since the start of the year, assessed at the end of each calendar quarter. Reduced from the originally planned 80% by the Omnibus.
See also: CBAM certificate, Sell-back / repurchase, Regulation (EU) 2025/2083 (the Omnibus)
- R
Regulation (EU) 2023/956#
The core law that created CBAM. It sets out the covered goods, who must comply, how emissions are counted, and the certificate and surrender system.
Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a Carbon Border Adjustment Mechanism. Published 16 May 2023; in force 17 May 2023. Supplemented and amended by implementing acts and by the 2025 Omnibus, Regulation (EU) 2025/2083.
See also: CBAM, Regulation (EU) 2025/2083 (the Omnibus), Annex I goods
Regulation (EU) 2025/2083 (the Omnibus)#
The 2025 "Omnibus" simplification that amended CBAM. It introduced the 50-tonne exemption, moved the first declaration deadline to 30 September, delayed certificate sales to February 2027, and cut the quarterly holding rule to 50%.
Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956. Published in the Official Journal on 17 October 2025; in force 20 October 2025. Part of the wider 2025 "Omnibus" simplification package.
See also: Regulation (EU) 2023/956, De minimis / 50-tonne threshold, CBAM declaration, Quarterly minimum holding, Omnibus simplification
Reporting declarant#
The party who filed the quarterly CBAM reports during the transitional period (2023–2025). A legacy role — in the definitive period the equivalent is the authorised CBAM declarant.
The party responsible for filing quarterly CBAM reports in the transitional CBAM Registry during the transitional period (Oct 2023–Dec 2025). Superseded by the authorised CBAM declarant in the definitive period.
See also: Transitional period, Transitional CBAM Registry, Authorised CBAM declarant
- S
Sell-back / repurchase#
Selling spare certificates back to the authority if you bought more than you needed. You request it by 30 June each year. The amount you can sell back is capped.
A request, by 30 June each year, for the authority to repurchase excess CBAM certificates via the common central platform. Under the Omnibus the repurchase cap is tied to the year's quarterly purchase obligation; confirm the exact formula in the implementing act.
See also: CBAM certificate, Quarterly minimum holding, Common central platform
Surrender#
Handing back CBAM certificates to cover the embedded emissions of the goods you imported that year. You surrender by 30 September of the following year, alongside your annual declaration.
The act of surrendering CBAM certificates equal to the total verified embedded emissions (adjusted for the CBAM factor and any foreign carbon price paid), by 30 September of the year following import.
See also: CBAM certificate, CBAM declaration, CBAM factor (phase-in factor), Excess-emissions penalty
- T
Transitional CBAM Registry#
The earlier reporting portal used during the transitional period (October 2023 to December 2025), where importers filed quarterly CBAM reports. It is a legacy term now — the definitive CBAM Registry has taken over.
The CBAM Transitional Registry used from October 2023 to December 2025 for quarterly reporting only. Superseded by the definitive CBAM Registry for the compliance regime.
See also: CBAM Registry, Transitional period, Reporting declarant
Transitional period#
The first phase of CBAM (1 October 2023 to 31 December 2025): reporting only, no payment and no certificates. Importers filed quarterly reports in the transitional registry.
The CBAM phase from 1 October 2023 to 31 December 2025, requiring quarterly reporting only, with no financial obligation or certificates. Light-touch, Member-State-set penalties (generally €10–€50/t) applied to reporting failures.
See also: Definitive period, Transitional CBAM Registry, Reporting declarant
This is guidance, not legal advice. Confirm with the official sources we link or a qualified adviser. Definitions reference Regulation (EU) 2023/956, as amended by the 2025 Omnibus, Regulation (EU) 2025/2083.
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