regulations
CBAM 2026 — EU Carbon Border Tax: What It Is
December 20, 20255 min readPaweł Dubel
Importing steel, aluminium or cement from outside the EU? From 2026, you'll pay for embedded CO₂ emissions. Learn how CBAM works and what it costs.
What is CBAM?
CBAM (Carbon Border Adjustment Mechanism) is the EU's carbon border tax that charges for CO₂ emissions embedded in imported goods. From 1 January 2026, importers of steel, aluminium, cement, fertilisers, hydrogen and electricity from non-EU countries must purchase CBAM certificates — priced at the EU ETS allowance rate (currently around €80-95 per tonne of CO₂).
CBAM levels the playing field between European producers (who already pay for emissions under ETS) and importers who previously could buy cheaper from countries with no carbon pricing. It is part of the EU's climate policy aiming for climate neutrality by 2050.
Calculate your estimated import costs: CALCULATOR. Find your goods' CN code: TARIFF FINDER.
Who does CBAM apply to?
CBAM applies to importers bringing in more than 50 tonnes of covered goods per year. It covers 6 high-emission sectors:
- Iron and steel — sheets, bars, tubes (CN codes 72xx, 73xx)
- Aluminium — profiles, sheets, foil (CN codes 76xx)
- Cement — clinker, Portland cement (CN codes 2523)
- Fertilisers — ammonia, urea, nitrates (CN codes 28, 31)
- Hydrogen (CN code 2804 10 00)
- Electricity (CN code 2716)
Small importer exemption: From 20 October 2025, importers bringing in less than 50 tonnes per year of CBAM goods (steel, aluminium, cement, fertilisers) are fully exempt. This exemption covers approximately 90% of importers (182,000 companies in the EU). Note: hydrogen and electricity are not covered by this exemption.
CBAM Timeline
Transitional period (1 Oct 2023 – 31 Dec 2025)
During the transitional period, importers submitted quarterly CBAM reports through the Transitional Registry — no payments required. This was time to collect data from suppliers and prepare for the definitive phase.
Definitive phase (from 1 Jan 2026)
From 1 January 2026, CBAM entered its definitive phase.
From 1 January 2026, importers must:
- Obtain authorised CBAM declarant status
- Report embedded emissions in imported goods
- Purchase and surrender CBAM certificates
CBAM certificate sales will begin on 1 February 2027 — certificates for 2026 emissions will be priced based on the 2026 quarterly average EUA price. From 2027, pricing will be weekly.
How to calculate CBAM liability?
CBAM liability = (volume [t] × embedded emissions [tCO₂e/t]) × certificate price [€/tCO₂e] × CBAM factor − deductions [€]
Step 1: Gather parameters
- Import volume (tonnes)
- Embedded emissions (tCO₂e per tonne of product)
- Country of production and any local carbon tax
- CN code (check in TARIFF FINDER)
Step 2: Apply the CBAM factor
The CBAM factor reflects the gradual phase-out of free allowances for EU producers:
| Year | CBAM Factor | EU Free Allowances |
|---|---|---|
| 2026 | 2.5% | 97.5% |
| 2027 | 5% | 95% |
| 2028 | 10% | 90% |
| 2029 | 22.5% | 77.5% |
| 2030 | 48.5% | 51.5% |
| 2034 | 100% | 0% |
Step 3: Account for deductions
If a carbon tax or CO₂ price has been paid in the country of production, you can deduct it from your CBAM liability (documentation required).
Calculate your costs: CALCULATOR
Calculation examples
Assumptions: EUA price = €80/tCO₂e, no deductions, 2026 CBAM factor = 2.5%.
Steel (sheets CN 7208)
- Volume: 50 t
- Embedded emissions: 2.0 tCO₂e/t
- Certificates: 50 × 2.0 = 100 tCO₂e
- Gross liability: 100 × €80 = €8,000
- 2026 liability (2.5%): €8,000 × 2.5% = €200
Aluminium (profiles CN 7604)
- Volume: 20 t
- Embedded emissions: 8.0 tCO₂e/t (primary aluminium)
- Certificates: 20 × 8.0 = 160 tCO₂e
- Gross liability: 160 × €80 = €12,800
- 2026 liability (2.5%): €12,800 × 2.5% = €320
Note: In 2034 at full CBAM implementation (100%), these amounts will be €8,000 and €12,800 respectively.
Common mistakes
- No supplier data → using Commission default values, which are typically inflated
- Wrong CN code → incorrect classification may result in wrong obligations or exclusion
- Confusing CBAM with EU ETS → CBAM covers imports, EU ETS covers EU installations
- Wrong units → t vs kg, tCO₂e/t vs kgCO₂e/kg
- Ignoring the 50 t/year threshold → check if you qualify for exemption
Frequently asked questions
Does CBAM apply only to raw materials or also finished products?
Currently — mainly raw materials and semi-finished products. The scope covers steel, aluminium, cement, fertilisers, hydrogen and electricity. From 2028, expansion to downstream products is planned.
How often do I need to report?
During the transitional period — quarterly. In the definitive phase, you submit an annual declaration by 30 September of the year following importation (first declaration for 2026 by 30 September 2027).
What if my supplier doesn't have emissions data?
You can use Commission default values. However, these are typically higher than actual emissions. In parallel, work on obtaining real data from suppliers — this will reduce certificate costs.
Do I need an EORI number?
Yes. An EORI number is required to register as an authorised CBAM declarant and to import goods covered by the mechanism.
Can I deduct carbon tax paid in the country of production?
Yes. If your supplier paid a carbon tax or CO₂ price in their country, you can deduct this amount from your CBAM liability. Documentation proving payment is required.
Legal basis
| Legal act | Scope |
|---|---|
| Regulation (EU) 2023/956 of 10 May 2023 | Establishes the CBAM |
| Regulation (EU) 2025/2083 of 8 October 2025 | CBAM simplifications (50 t threshold, deadlines) |
| Implementing Regulation (EU) 2023/1773 | Reporting rules for transitional period |
| Directive 2003/87/EC (EU ETS) | Emissions trading system — price benchmark |
Useful tools
- CALCULATOR — calculate estimated certificate costs
- TARIFF FINDER — find your goods' CN code
- [DUTY CALCULATOR] — calculate full import costs
Official sources:
Summary
- CBAM applies from 1 January 2026 — importers must report and purchase certificates
- 50 t/year threshold — importers below this are exempt (except hydrogen and electricity)
- CBAM certificates — priced at EU ETS rate (approx. €80-95/tCO₂e)
- CBAM factor — increases from 2.5% (2026) to 100% (2034)
- First compliance deadline — annual declaration for 2026 by 30 September 2027
This article is for informational purposes only and does not constitute legal or tax advice. Legal status as of January 2026.
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