Regulations · Exporters

EU Carbon Border Adjustment Mechanism

CBAM puts a carbon price on certain goods entering the EU. The definitive period started on 1 January 2026. The EU importer pays, but the data comes from you.

What it is

Regulation (EU) 2023/956 covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity.

From 2026 importers need authorised CBAM declarant status, declare embedded emissions each year and surrender CBAM certificates priced on the EU ETS.

Regulation (EU) 2025/2083 simplified the regime, including a 50 tonne per year mass threshold below which importers are exempt.

The charge phases in as EU free allocation phases out. Only a small share of embedded emissions is charged in 2026 and the share rises each year to 2034.

Who it applies to

EU importers of covered goods above the 50 tonne annual threshold.
GCC producers who sell to them, in practice aluminium, steel and fertiliser exporters. Your buyer needs installation-level emissions data that can be verified.

Key dates

1 Oct 2023 to 31 Dec 2025	Transitional period, reporting only.
1 Jan 2026	Definitive period begins. Emissions in 2026 imports carry a certificate obligation.
1 Feb 2027	Sale of CBAM certificates begins.
30 Sep 2027	First annual declaration and surrender of certificates, for 2026 imports.

What to do now

List your EU shipments by CN code and volume, and identify which buyers exceed the threshold.
Calculate actual embedded emissions per installation using the EU methodology. Default values are usually less favourable.
Prepare for third-party verification of your emissions data.
Agree with buyers who carries the cost and how it is priced into contracts.

Sources

Summary for orientation only, not legal advice. Always check the current text with the issuing authority.