EU CBAM: What Importers of Steel, Aluminum, Cement & Fertilizers Owe, and When

CBAM is an EU charge on the carbon emitted in making certain imported goods: iron and steel, aluminum, cement, fertilizers, electricity and hydrogen. EU producers of those goods pay for their emissions under the EU Emissions Trading System (ETS). CBAM makes importers pay a matching price, so that production does not simply move to countries with weaker carbon rules. Importers do it by buying and surrendering CBAM certificates, one per tonne of CO₂e embedded in their imports, priced from EU ETS allowance auctions.

The goods listed in Annex I of Regulation (EU) 2023/956: iron and steel (chapter 72 apart from most ferro-alloys and scrap, plus tubes, structures, containers, fasteners and other articles from chapter 73), aluminum (unwrought aluminum and most products and articles of it), cement and clinker, nitrogen fertilizers together with ammonia, nitric acid and potassium nitrate, electricity, and hydrogen. Goods originating in Iceland, Liechtenstein, Norway and Switzerland are outside CBAM. The regulation asked the Commission to assess adding other goods at risk of carbon leakage, organic chemicals and polymers in particular, with a timetable ending in 2030.

Yes. Since 1 January 2026, an importer is exempt if the goods it imports in a calendar year total no more than 50 tonnes net mass, counted across all CBAM goods together. If it goes over 50 tonnes, every import that year is covered, not just the excess. The threshold does not apply to electricity or hydrogen. It replaced the earlier exemption for consignments of negligible value.

Each certificate covers one tonne of CO₂e. For goods imported in 2026 the Commission sets a quarterly price from EU ETS auction prices: €75.36 for Q1, €75.28 for Q2 and €82.32 for Q3 2026. The Q4 price is due on 4 January 2027, and from 2027 the price is set weekly. How many certificates you need per tonne of goods depends on its embedded emissions, less an adjustment for the free ETS allowances EU producers of the same goods still receive, and less any carbon price effectively paid where the goods were made.

Certificates for goods imported in 2026 go on sale on 1 February 2027. The first annual CBAM declaration, for 2026 imports, and the surrender of the matching certificates are both due by 30 September 2027. After that the deadline is 30 September every year, for the previous calendar year. From 2027 you must also hold, at the end of each quarter, certificates for at least 50% of the emissions embedded in that year's imports so far. The transitional period (October 2023 to December 2025) required quarterly reports only, with no payment.

Only if you applied for authorised CBAM declarant status by 31 March 2026. In that case you may keep importing until your national authority decides. If it refuses, it works out the emissions embedded in what you imported since 1 January 2026 from default values, and penalties are calculated on them. Importers who stay under the 50-tonne threshold do not need the status.

CBAM is charged on imports into the EU, so it falls on whoever imports there, not on the exporter. An importer established in an EU member state needs authorised CBAM declarant status before importing, unless it stays under the 50-tonne threshold. If the importer is not established in the EU, for example a US company importing in its own name, its indirect customs representative must hold the status and takes on the importer's CBAM obligations. If you are a US exporter selling to an EU buyer, the buyer carries the CBAM cost and will take it into account in what it pays you.

Yes, under conditions. A declarant can claim fewer certificates for a carbon price effectively paid in the country where the goods were made, net of any rebate or other compensation, with documents certified by an independent person. Where the declarant uses default values instead of actual emissions, the reduction can only be claimed against yearly default carbon prices, which the Commission may publish for third countries from 2027. Goods originating in Iceland, Liechtenstein, Norway and Switzerland are outside CBAM altogether.

Embedded emissions are the greenhouse gases emitted in producing the goods: carbon dioxide for all of them, plus nitrous oxide for some fertilizers and perfluorocarbons for aluminum. For goods other than electricity, the declarant uses either the producer's actual emissions, checked by an accredited verifier, or the default values published by the European Commission. Actual data pays off when the producer is cleaner than the default.