Free tool

Does CBAM apply to me?

If a customer or customs broker just told you that you might need to be a CBAM declarant and you are not sure what that means, start here. Answer a few plain-English questions about what you import and you will get a tailored steer: whether CBAM applies, whether the 50-tonne threshold exempts you, and what to do next.

Last updated: 8 June 2026

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Do you import any of these into the EU: cement, iron & steel, aluminium, fertilisers, electricity or hydrogen?

These are the six sectors CBAM covers. It reaches the goods themselves, plus some downstream steel and aluminium items such as screws, bolts, nuts, washers, tubes, pipes and fittings. Think about what you bring into the EU customs territory, not what you make from it afterwards.

The short version

How CBAM scope works

Four things decide whether CBAM lands on you: the goods you import, where they originate, how much you import in a year, and who acts as importer of record. Here is each in plain English.

TL;DR

CBAM applies if you import cement, iron & steel, aluminium, fertilisers, electricity or hydrogen into the EU. But if your combined annual net mass of the first four is 50 tonnes or less, you are exempt under the de minimis. Electricity and hydrogen are covered at any volume, with no exemption. Goods originating in Iceland, Liechtenstein, Norway or Switzerland are excluded. Above the threshold you must be, or import through, an authorised CBAM declarant.

The six covered sectors

CBAM covers six sectors, defined by their CN (Combined Nomenclature) customs codes in Annex I of the regulation: cement, iron & steel, aluminium, fertilisers, electricity and hydrogen. Coverage follows the CN code of the good you import, not what you make from it: a steel sheet is covered, but a car body made of steel is not. To stop importers sidestepping the rules, some downstream steel and aluminium items are deliberately in scope, notably fasteners (screws, bolts, nuts, washers) and tubes, pipes and fittings. Regulation (EU) 2023/956, Annex I

The 50-tonne mass de minimis

The headline change from the 2025 Omnibus simplification is a new 50-tonne de minimis. 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. It is measured per importer per year and is cumulative across those four sectors, so several smaller shipments add up. It replaced the old EUR 150-per-consignment rule, and is estimated to exempt around 90% of importers while still capturing more than 99% of in-scope emissions. DG TAXUD, 2025 CBAM simplification

Electricity and hydrogen are the exception

The 50-tonne threshold does not apply to electricity or hydrogen. They are in scope at any volume, even a small or one-off import. If you import either, you need authorised CBAM declarant status regardless of quantity.

Excluded ETS-linked origins

Goods originating in countries linked to the EU Emissions Trading System are excluded from CBAM: today that means Iceland, Liechtenstein, Norway and Switzerland, plus certain small territories. The test follows the customs non-preferential origin of the good, not where you bought it, so goods routed through an excluded country but originating elsewhere can still be in scope.

Importer or indirect representative

Above the threshold, only an authorised CBAM declarant may import covered goods. An EU-established importer normally becomes the declarant itself. An importer not established in the EU must act through an EU-established indirect customs representative, who becomes the authorised declarant and assumes the same obligations and penalties. Apply via the CBAM Registry, using an EORI number; the National Competent Authority can take up to 120 days to assess. DG TAXUD, CBAM

One part is still moving

The Commission has proposed extending CBAM to about 180 steel- and aluminium-intensive downstream products (and possibly some chemicals) from 2028. It is a proposal, not law, so we have not built it into the tool. If it is adopted, we will update this page and tell subscribers of The CBAM Brief.

Scope questions people ask

Does CBAM apply to me?

If you import cement, iron & steel, aluminium, fertilisers, electricity or hydrogen into the EU, potentially yes. But if your total annual net mass of cement, steel, aluminium and fertilisers is 50 tonnes or less, you are exempt under the de minimis introduced by the 2025 Omnibus. Electricity and hydrogen are different: they are covered at any volume, with no exemption. Goods originating in Iceland, Liechtenstein, Norway or Switzerland are excluded because those countries are linked to the EU Emissions Trading System.

What is the CBAM threshold?

It is a 50-tonne cumulative annual net-mass de minimis, in force since the 2025 Omnibus (Regulation (EU) 2025/2083). If your combined annual imports of cement, iron & steel, aluminium and fertilisers weigh 50 tonnes or less, you are exempt from authorisation, reporting and surrender. It replaced the old EUR 150-per-consignment rule and is estimated to exempt around 90% of importers while still capturing more than 99% of emissions. It does not apply to electricity or hydrogen.

Who needs to register for CBAM?

From 1 January 2026, only an authorised CBAM declarant may import covered goods above the 50-tonne threshold (and any volume of electricity or hydrogen). An EU-established importer normally becomes the authorised declarant itself; an importer not established in the EU must act through an EU-established indirect customs representative, who becomes the declarant. You apply via the CBAM Registry (the Authorisation Management Module), you need an EORI number, and the National Competent Authority can take up to 120 days to assess the application.

Is my product covered by CBAM?

Coverage is driven by the CN (Combined Nomenclature) customs code of the good you import, as listed in Annex I of Regulation (EU) 2023/956. A steel sheet is covered; a car body made of steel is not, because it sits under a different CN code. To prevent circumvention, some downstream steel and aluminium items are in scope, notably fasteners (screws, bolts, nuts, washers) and tubes, pipes and fittings. Most complex finished products such as vehicles, machinery and appliances are not. Check your exact CN code against Annex I or our goods and CN codes page.

This is guidance to help you understand CBAM, not legal or tax advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]European Commission, DG TAXUD, Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
  2. [2]DG TAXUD, Officially published: Simplifications for CBAM (2025 Omnibus, Reg (EU) 2025/2083)retrieved 8 Jun 2026
  3. [3]EUR-Lex, Carbon Border Adjustment Mechanism summary (Regulation (EU) 2023/956)retrieved 8 Jun 2026