Knowledge base

CBAM versus EU sanctions, how they differ and why you check both

Updated: 26 June 2026

CBAM, the Carbon Border Adjustment Mechanism, and EU goods sanctions both use CN codes, but they pursue completely different aims. Sanctions prohibit trade in certain goods with the Russia and Belarus regimes, while CBAM imposes reporting and payment obligations on imports of carbon-intensive goods. The same code may be subject to both, which is why an importer checks each separately.

Two different aims of the same code language

What sanctions and CBAM share is that they identify goods by CN codes. That is where the similarity ends. Sanctions are a security policy instrument that prohibits or restricts trade with certain countries and entities. CBAM is a climate policy instrument that equalises the cost of emissions between production in the EU and imports.

In practice this means you answer two different questions. With sanctions you ask whether the goods may be moved. With CBAM you ask whether the import gives rise to reporting and payment obligations, and to what extent.

Which goods CBAM covers

CBAM in its current shape covers selected carbon-intensive sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The specific CN codes of these sectors are listed in the annex to the CBAM regulation, so here too the starting point is the correct code.

Importantly, the scopes of CBAM and sanctions partly overlap, for example in iron and steel, but they are not identical. Goods may be covered by CBAM and at the same time not be covered by sanctions, or the other way round. That is why it is not enough to check one regime and assume the status under the other.

Importer obligations and deadlines

CBAM entered a transitional period with reporting obligations, and from 2026 it moves into a phase with payment obligations, in which the importer buys and surrenders CBAM certificates corresponding to the emissions embedded in the imported goods. Added to this is the status of authorised CBAM declarant.

For a company this means a separate compliance stream alongside sanctions: establishing whether a code is covered by CBAM, collecting emissions data from the supplier and reporting on time. You check the CBAM status of a code in a separate section of the tool, just like the sanctions status.

How to fold the check into one procedure

The simplest approach is to treat it as three questions asked at every import of sensitive goods: is the CN code subject to goods sanctions, is the counterparty on a sanctions list, and is the code covered by CBAM. Three answers, three traces in the documentation.

This approach closes the typical gap where a company focuses on one regime and skips the other. With steel, aluminium or fertilisers, missing CBAM is as costly as missing sanctions, only the consequences are of a different nature.

Frequently asked questions

Does CBAM prohibit imports?

No. CBAM does not prohibit trade. It imposes reporting and, from 2026, payment obligations on imports of carbon-intensive goods. Trade bans stem from sanctions, that is the separate 833/2014 and 765/2006 regimes.

Are goods covered by CBAM also covered by sanctions?

Not necessarily. The scopes partly overlap, for example in iron and steel, but these are two different regimes. You have to check both, because the status under one does not determine the status under the other.

Where do I check whether a code is covered by CBAM?

In the separate CBAM section of the tool, where by CN code you see whether the import is covered by the mechanism, together with information about the sector and the deadlines.

CBAM by CN code Check a CN code Goods vs persons and entities

More in the knowledge base

Informational content based on EU regulations (833/2014, 765/2006) and the act of 13 April 2022 (Journal of Laws 2022 item 835). It does not constitute legal or customs advice. The binding source is the text of the act in EUR-Lex and the decision of the customs authorities. In case of doubt, consult an adviser.