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CBAM • EU carbon charge on imports

CBAM: goods, threshold and deadlines

Does CBAM apply to you?

CBAM is the EU carbon charge on imports. It applies to goods from 6 sectors: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.

Phase, threshold and importer duties

The CBAM definitive period has applied since 01/01/2026 (source: Regulation (EU) 2023/956, Article 36(2)(b)). If your total imports of CBAM goods exceed 50 t of net mass in a year, you need authorised CBAM declarant status. Each year you declare the emissions embedded in the goods and surrender CBAM certificates to cover them. The threshold does not apply to electricity or hydrogen.

Basis: Regulation (EU) 2023/956, Annex I.

CBAM is not sanctions

CBAM does not ban trade. It is a charge for CO2 emissions on imports: the importer reports the emissions and covers them with certificates. Sanctions are separate restrictions or bans targeting a country (e.g. Russia, Regulation 833/2014). Goods can fall under CBAM, sanctions, both or neither. So check both separately.

Sectors covered by CBAM

On each sector page: the CN codes in Annex I as worded in the act, exceptions, greenhouse gases, Annex II and the threshold.

50 t threshold calculatorEnter annual net masses by sector and check whether total imports exceed the Article 2a de minimis threshold.Calculate the threshold

Key deadlines

  • The CBAM definitive period has applied since 01/01/2026 (source: Regulation (EU) 2023/956, Article 36(2)(b)).
  • The authorised CBAM declarant application is submitted before the first import; an application submitted by 31/03/2026 allowed imports to continue until the decision (Article 17(7a)) (source: Regulation (EU) 2023/956, Article 17(7a)).
  • First certificate surrender: 30/09/2027 (for 2026) (source: Regulation (EU) 2023/956, Article 22(1)).
  • De minimis threshold: 50 t of net mass per year, in total per importer (except hydrogen and electricity).

How to compare a CN code with Annex I, step by step

  1. Compare the import CN code with Annex ITake the 8-digit CN code of the goods and compare it with the entries in Annex I to Regulation (EU) 2023/956.
  2. Estimate the annual volumeAdd up the net mass of all CBAM goods you import in the calendar year, across all CN codes together (electricity and hydrogen are outside the threshold). If the total does not exceed 50 t, the de minimis exemption applies. Once exceeded, the obligations cover all imports of that year, not just the excess.
  3. Obtain authorised CBAM declarant statusThe application for authorised CBAM declarant status is submitted before the first import (Articles 4 and 5). The Article 17(7a) deadline allowed imports to continue while an application submitted by 31/03/2026 was being processed (source: Regulation (EU) 2023/956, Article 17(7a)).
  4. Report emissions and surrender certificatesReport embedded emissions and surrender CBAM certificates. The first certificate surrender, for 2026, is due on 30/09/2027 (source: Regulation (EU) 2023/956, Article 22(1)).
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Related resources

Frequently asked questions about CBAM

How does CBAM differ from EU sanctions?

CBAM is not a trade ban. It is the EU charge for CO2 emissions on imports of high-emission goods. The importer reports the emissions and covers them with CBAM certificates. Sanctions are restrictions or bans on import and export targeting a specific country. Goods can be covered by CBAM, by sanctions, by both, or by neither.

How do I compare a CN code with Annex I?

Compare the CN code of the goods with the entries in Annex I to Regulation (EU) 2023/956. Annex I covers 6 sectors: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Entries can be four-digit or cover a whole chapter (72), and they have exceptions and "ex" entries, so the full code and the description of the goods matter. The entries of each sector, from the text of the act, are on the sector pages.

When does the definitive CBAM period start?

The CBAM definitive period has applied since 01/01/2026 (source: Regulation (EU) 2023/956, Article 36(2)(b)). In the definitive period an importer whose total imports of CBAM goods in a year exceed 50 t of net mass must hold authorised CBAM declarant status, declare embedded emissions and surrender CBAM certificates.

What is the CBAM de minimis threshold?

The threshold is 50 t of net mass per calendar year per importer, in total for goods under all CN codes (Article 2a(1) and Annex VII, point 1). If the total does not exceed 50 t, the importer is exempt from the obligations under the Regulation. Once exceeded, the obligations cover the emissions embedded in all goods of that year (Article 2a(2)). Article 2a does not apply to imports of electricity or hydrogen.

Do I pay for CBAM immediately at import?

No. CBAM is not a duty paid at clearance. The importer buys and surrenders CBAM certificates matching the embedded emissions. The first certificate surrender, for 2026, is due on 30/09/2027 (source: Regulation (EU) 2023/956, Article 22(1)).

Informational page, not legal or tax advice. Confirm the current scope and CBAM mechanics in Regulation 2023/956 and implementing acts on EUR-Lex.