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CBAM

The carbon price on the heavy goods you import into the EU.

cbam@1.0.3

Educational guide only — this module is not part of the current public offer.

What is CBAM?

The Carbon Border Adjustment Mechanism (CBAM) puts a carbon price on certain goods imported into the EU, so that imports carry a cost for their embedded emissions comparable to what EU producers already pay under the EU Emissions Trading System. The goal is to stop 'carbon leakage' — production moving to countries with weaker climate rules.

SourceRegulation (EU) 2023/956, Art. 1 (subject matter) · captured 2026-07-11

It covers the most carbon-intensive traded goods: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. Whether a specific product is in scope is decided by its 8-digit Combined Nomenclature (CN) customs code against Annex I of the regulation.

SourceRegulation (EU) 2023/956, Annex I (list of goods and greenhouse gases) · captured 2026-07-11

From 1 January 2026 the definitive regime applies: in-scope goods may be imported only by an 'authorised CBAM declarant', who each year submits a CBAM declaration reporting the embedded emissions of the goods imported and surrenders CBAM certificates to cover them. Before that, from October 2023, there was a reporting-only transitional period with no certificates.

SourceRegulation (EU) 2023/956, Art. 4-6 + Art. 36(2), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

Embedded emissions can be reported using either the actual measured values from the installation that produced the goods, or official default values published by the Commission. The actual-value path must be checked by an accredited verifier; the default-value path is self-serve. Clearlane prepares a cited, human-readable declaration draft from your emissions data; it does not submit the annual declaration to the CBAM Registry.

SourceRegulation (EU) 2023/956, Art. 7-8; Comm. Impl. Reg. (EU) 2025/2621 (default values) · captured 2026-07-11

Who must comply with CBAM?

From 1 January 2026, only an authorised CBAM declarant may import goods listed in Annex I into the EU customs territory. Becoming authorised is the gateway obligation — without that status the goods cannot be imported.

SourceRegulation (EU) 2023/956, Art. 4 + Art. 5, as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

There is a small-quantity relief: a 50-tonne net-mass de-minimis exemption per importer per calendar year, introduced by the Omnibus. Stay at or below it across all your in-scope goods and the exemption applies — but electricity and hydrogen are explicitly excluded from this relief.

SourceRegulation (EU) 2023/956, Art. 2a + Annex VII(1), as inserted by Regulation (EU) 2025/2083; Art. 2a(4) (electricity/hydrogen excluded) · captured 2026-07-11

Does this apply to me?

Answer a few questions. The verdict is this regulation's own cited scope data — no account, and nothing you answer is sent to us. The last step downloads one static table of those cited answers from this site, chosen by what you answered.

Turn on JavaScript to run the interactive check. The questions and options are listed below.

  1. Do you import any of these goods into the EU customs territory?

    Cement, iron & steel, aluminium, fertilisers, electricity, or hydrogen.

    • Yes
    • No
    • Not sure

  2. Which group best matches what you import?

    • Cement
    • Iron & steel
    • Aluminium
    • Fertilisers
    • Electricity
    • Hydrogen
    • None of these / not sure

  3. Do you expect to import more than 50 tonnes of these goods per calendar year?

    The 50 t de-minimis exemption is cumulative across the year — but it never applies to electricity or hydrogen.

    • Yes, over 50 t
    • No, 50 t or less
    • Not sure

  4. Where do the goods originate?

    Excluded places are EU Member States, Iceland, Liechtenstein, Norway, Switzerland, Büsingen, Heligoland, Livigno, Ceuta and Melilla.

    • Another non-EU country
    • EU or a listed excluded place
    • Not sure

  5. What is your position on the import?

    • I am the importer (authorised CBAM declarant)
    • I act as the indirect customs representative
    • Neither / not sure

When are the deadlines?

  1. 1 October 2023

    Transitional period

    Reporting-only period (1 Oct 2023 – 31 Dec 2025): quarterly CBAM reports, but no authorised-declarant status, no certificates, and no verifier requirement. The final quarterly report (Q4 2025) was due 31 January 2026.

    SourceRegulation (EU) 2023/956, Art. 32 + Art. 36(2) · captured 2026-07-11

  2. 1 January 2026

    Definitive regime starts

    The core obligations switch on: only an authorised declarant may import, embedded emissions must be determined, and the annual declaration and certificate surrender begin to apply.

    SourceRegulation (EU) 2023/956, Art. 36(2)(b), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

  3. 1 January 2027

    Quarterly certificate holding

    From this date the authorised declarant must hold, at the end of each quarter, CBAM certificates covering at least 50% of the embedded emissions accumulated since the start of the year.

    SourceRegulation (EU) 2023/956, Art. 22(2) + Art. 36(2)(c), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

  4. 1 February 2027

    Certificate sales open

    Member States begin selling CBAM certificates on the common central platform — the point from which you can actually buy the certificates you later surrender.

    SourceRegulation (EU) 2023/956, Art. 20(1) + Art. 36(2)(d), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

  5. 30 September 2027

    First annual declaration

    The first annual CBAM declaration (covering import year 2026) is due, together with the first surrender of certificates. The deadline is 30 September each year — moved by the Omnibus from the original 31 May.

    SourceRegulation (EU) 2023/956, Art. 6(1) + Art. 22(1), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

How do you actually comply?

  1. Collect emissions

    The declaration has to report the embedded emissions of each type of good. So the first step is to attach each imported good and capture its emissions data — either the actual values from the producing installation or the official default values.

    SourceRegulation (EU) 2023/956, Art. 6(2) + Art. 7 · captured 2026-07-11

  2. Validate

    The law fixes what every goods line must carry: the CN code, the quantity, the country of origin and the embedded emissions. Validation runs the cited rule pack over the assembled declaration so gaps and malformed fields surface before filing.

    SourceRegulation (EU) 2023/956, Art. 6(2)(a)-(d) · captured 2026-07-11

  3. Completeness check

    Where a line uses actual measured values, those emissions must be verified by an accredited verifier; the default-value path carries no such obligation. The completeness pass records a reproducible evidence bundle and flags any actual-value line missing its verification report.

    SourceRegulation (EU) 2023/956, Art. 8(1) · captured 2026-07-11

  4. Declare

    The annual CBAM declaration is due by 30 September for the previous import year. 'Ready' here means the recorded evidence package is complete and can be downloaded for the external declaration process; Clearlane does not route a verifier or file with the registry.

    SourceRegulation (EU) 2023/956, Art. 6(1) + Art. 22(1), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

What do the terms mean?

Authorised CBAM declarant

The status you must hold to import Annex I goods into the EU from 2026. The authorised declarant files the annual declaration and surrenders the certificates.

SourceRegulation (EU) 2023/956, Art. 4 + Art. 5, as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

Embedded emissions

The greenhouse gas emissions released during the production of the imported goods — the quantity CBAM puts a price on. Determined per Annex IV, either as actual values or defaults.

SourceRegulation (EU) 2023/956, Art. 7 + Annex IV · captured 2026-07-11

Direct vs indirect emissions

Direct emissions come from the production process itself; indirect emissions come from the electricity used to make the goods. For the goods listed in Annex II, only direct emissions count.

SourceRegulation (EU) 2023/956, Art. 7 + Annex II · captured 2026-07-11

Default values

Official emission intensities published by the Commission (with a sectoral mark-up). Using them is the self-serve path — no verifier is required. Clearlane fills them in by CN code and country of origin when a line omits actual figures.

SourceRegulation (EU) 2023/956, Art. 7(2); Comm. Impl. Reg. (EU) 2025/2621 · captured 2026-07-11

Actual values

Emissions measured at the installation that produced the goods. They can lower your carbon cost versus defaults, but they must be checked by an accredited verifier.

SourceRegulation (EU) 2023/956, Art. 8(1) · captured 2026-07-11

Accredited verifier

An independent body, accredited under the regulation, that verifies actual-value embedded emissions. Required only on the actual-value path — the default path needs none.

SourceRegulation (EU) 2023/956, Art. 8(1); Comm. Impl. Reg. (EU) 2025/2546 · captured 2026-07-11

CBAM certificate

The instrument you surrender to cover the embedded emissions you declared — one certificate per tonne of CO2e, bought from the common central platform.

SourceRegulation (EU) 2023/956, Art. 20 + Art. 22 · captured 2026-07-11

Certificate price

The price of a CBAM certificate, set as the weekly average of EU ETS auction closing prices (a quarterly-average derogation applied for 2026).

SourceRegulation (EU) 2023/956, Art. 21(1)/(1a); Comm. Impl. Reg. (EU) 2025/2548 · captured 2026-07-11

De-minimis (50 tonnes)

A relief from the CBAM obligation for importers whose cumulative in-scope net mass does not exceed 50 tonnes per calendar year. Electricity and hydrogen never qualify for it.

SourceRegulation (EU) 2023/956, Art. 2a + Annex VII(1), as inserted by Regulation (EU) 2025/2083 · captured 2026-07-11

CN code

The 8-digit Combined Nomenclature customs code that identifies a good. CBAM scope is decided at the 8-digit CN level, and each declaration line carries one.

SourceCombined Nomenclature, Annex I to Council Regulation (EEC) No 2658/87 · captured 2026-07-11

Annual CBAM declaration

The yearly submission, due 30 September for the prior import year, reporting each good's quantity and embedded emissions and the certificates to surrender.

SourceRegulation (EU) 2023/956, Art. 6, as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

Transitional period

The reporting-only phase from 1 Oct 2023 to 31 Dec 2025 — quarterly reports, but no certificates and no verifier requirement, before the definitive regime.

SourceRegulation (EU) 2023/956, Art. 32 · captured 2026-07-11

What happens if you don't comply?

CBAM is structured as an import gate: from 1 January 2026, goods listed in Annex I may be imported into the EU customs territory only by an authorised CBAM declarant. Without that authorisation the in-scope goods cannot lawfully be imported at all.

SourceRegulation (EU) 2023/956, Art. 4 + Art. 5, as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

Being authorised is not the end of it: the declarant must file the annual declaration and surrender enough certificates to cover the declared embedded emissions, and from 2027 hold at least 50% of the running total each quarter. Under-holding or under-declaring leaves an open obligation the registry tracks against you.

SourceRegulation (EU) 2023/956, Art. 22(1)-(2), as amended by Regulation (EU) 2025/2083 · captured 2026-07-11

Technical references

The precise, checkable material behind this guide — formats, error meanings and free tools.

SourceRegulation (EU) 2023/956 (CBAM), as amended by Regulation (EU) 2025/2083 (Omnibus). · cbam@1.0.3