Eleven questions EU importers ask about CBAM, answered from the acts

By Ahmed Medhat · Published27 September 2026

These are the questions EU importers ask us most, answered from the acts themselves. Every answer names the article it rests on, so you can check it; an article with no act named is in Regulation (EU) 2023/956. Where an answer depends on your goods, your supplier or your customs set-up, we say so rather than guess.

1. Does CBAM apply to my imports?

To the goods listed in Annex I of Regulation (EU) 2023/956: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, each by CN code. Products that come out of inward processing of those goods are covered too, even when they are not Annex I goods themselves; what you declare is the emissions embedded in the Annex I goods that went into the processing (Articles 2(1) and 6(3)).

Then there is the threshold. An importer is exempt when the net mass of its imports "in a given calendar year does not cumulatively exceed the single mass-based threshold" (Article 2a(1)), which Annex VII, point 1, sets at 50 tonnes. The 50 tonnes are counted across all CN codes together, per importer and per calendar year. Cross them and every tonne imported that year is in, not just the tonnes above 50 (Article 2a(2)). Electricity and hydrogen get no threshold at all (Article 2a(4)).

Our 50-tonne checker runs that test on your own tonnages.

2. Do I need to be an authorised CBAM declarant?

Yes, if you expect to cross the threshold. "Goods shall be imported into the customs territory of the Union only by an authorised CBAM declarant" (Article 4). An importer established in a Member State applies before importing (Article 5(1)), and under the threshold rule it applies "in cases where that importer expects to exceed the single mass-based threshold" (Article 5(1b)).

An importer or indirect customs representative that applied by 31 March 2026 may keep importing provisionally until the competent authority decides (Article 17(7a)).

Not established in the EU? Then your indirect customs representative must hold the status, whatever your tonnage (Article 5(2)), and carries the importer's obligations for the goods it imports on your behalf (Article 5(2a)).

3. What if I cross 50 tonnes without the status?

The penalty is set at three to five times the penalty for an unsurrendered certificate, and it is counted on all the emissions in everything you imported that year (Article 26(2) and (2a)). Paying it releases you from the declaration and the surrender for those imports. The competent authority may reduce it if you went over by no more than 10 % of the threshold, or if you applied by 31 March 2026 and were importing provisionally (Article 17(7a)), but never below the penalty in Article 26(1).

4. What do I file, and when?

As the authorised CBAM declarant, you submit one CBAM declaration a year, in the CBAM registry, by 30 September, "and for the first time in 2027 for the year 2026" (Article 6(1)). It states the quantity of each type of goods, the embedded emissions in them, the number of certificates to surrender, and any verification reports (Article 6(2)). The quantity includes goods imported below the threshold.

You can have someone else submit it for you, but the obligations stay yours (Article 5(7a)).

5. How are the embedded emissions worked out?

For goods other than electricity, two ways, per good: from actual emissions, with your supplier's installation data, or from the default values the Commission publishes (Article 7(2)). Imported electricity is taken on default values unless you show the criteria for actual emissions are met (Article 7(3)). For the goods in Annex II only direct emissions count (Article 7(1)).

6. What does it cost to use default values?

More than the default itself. For cement, iron and steel, aluminium and hydrogen, the default for total emissions is raised by a mark-up of 10 % for 2026, 20 % for 2027 and 30 % from 2028. For fertilisers the mark-up is 1 % from 2026 on (IR (EU) 2026/1740, Annex I, opening paragraph).

And the country matters. If the country of origin is not listed, or is listed with no value for that good, the value comes from the table "Other countries and territories" (same paragraph).

7. When do I need a verifier?

When you declare actual emissions. The declarant must then make sure the totals are "verified by a verifier accredited pursuant to Article 18" (Article 8(1)). Declaring on default values alone needs no verification report: the declaration carries reports only "where applicable" (Article 6(2)(d)).

8. How many certificates do I surrender, and at what price?

A CBAM certificate corresponds to one tonne of CO2e of embedded emissions (Article 3). You surrender one per tonne, after two reductions. First, the carbon price already paid in a third country (Article 9). Second, an adjustment for the free allocation EU producers of the same goods still receive (Article 31). That second one shrinks each year with the CBAM factor, which is 97.5 % for 2026, 95 % for 2027 and 90 % for 2028, falling to 14 % for 2033; from 2034 no CBAM factor applies (Directive 2003/87/EC, Article 10a(1a)).

The price for 2026 imports is the average EU ETS auction price of the quarter you imported in (Article 21(1a)). From 1 January 2027 it is calculated every calendar week (Article 21(1); IR (EU) 2025/2548, Article 5(1)). The certificates for the year are surrendered by 30 September of the following year (Article 22(1)).

9. Do I have to hold certificates during the year?

From 2027, yes. At the end of each quarter your registry account must hold certificates for at least 50 % of the embedded emissions in everything imported since 1 January (Article 22(2)). You can measure that on default values without the mark-up, or on the certificates you surrendered for the same goods and countries the year before. If you cross the 50-tonne threshold part-way through the year, the holding applies from the end of the quarter after the one in which you crossed it (Article 22(2a)).

10. Can I deduct a carbon price my supplier paid?

There are two routes. If you declare actual emissions, you can claim for the carbon price that "has been effectively paid" in the third country, and any rebate or other compensation available there that would have lowered it is taken into account (Article 9(1)). Keep the evidence until the end of the fourth year after the year the declaration is submitted (Article 9(2) and (3)).

If you declare on default values, a reduction "may be claimed only by a reference to yearly default carbon prices" (Article 9(4)). From 2027 the Commission may determine those prices for third countries with carbon pricing rules and make them available in the CBAM registry.

11. What if I miss the 30 September surrender?

You pay the EU ETS excess emissions penalty for each certificate you did not surrender, at the level that applied in the year you imported the goods (Article 26(1)). Paying it does not cancel the debt: you still owe the certificates (Article 26(3)). If the shortfall came from wrong information supplied by your operator, your verifier, or whoever certified the carbon price, the competent authority may reduce the penalty (Article 26(1a)).

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