Resources · Regulation
The carbon border adjustment has been in its definitive regime since Jan 1, 2026. Certificates go on sale on Feb 1, 2027, and the first surrender is due on Sep 30, 2027. Below 50 tonnes a year, CBAM does not apply.
A carbon price on imports of emission-intensive goods into the EU, set out in Regulation (EU) 2023/956. It is designed to prevent carbon leakage and mirrors the EU ETS price.
Iron and steel, aluminium, cement, fertilisers, electricity and hydrogen, plus certain upstream products.
Transitional period Oct 1, 2023 to Dec 31, 2025 with quarterly reports. Definitive regime since Jan 1, 2026. Certificate sales from Feb 1, 2027, first surrender by Sep 30, 2027.
Below 50 tonnes of net mass per calendar year all CBAM obligations fall away — aggregated across all commodity codes. Electricity and hydrogen are excluded.
The Carbon Border Adjustment Mechanism puts a carbon price on imports of certain emission-intensive goods. The aim is to prevent carbon leakage: where EU producers pay for their emissions through the Emissions Trading System, imports from countries with lower or no carbon prices should not gain an advantage. The legal basis is Regulation (EU) 2023/956.
For many companies this is the decisive point. Regulation (EU) 2025/2083 (Official Journal Oct 17, 2025) introduced a mass-based threshold. It is adopted law, not a plan.
CBAM arrived in two phases. The years are often confused, because the definitive regime and certificate trading do not start at the same time.
The certificate price is tied to the EU ETS. In 2026 the quarterly average of auction closing prices applies; from 2027 the weekly average. From 2027, declarants must hold certificates covering at least 50% of their embedded emissions at the end of each quarter. In parallel, free ETS allocation for the sectors concerned is phased out.
The core of CBAM is determining the greenhouse gas emissions embedded in imported goods. Importers have two routes.
On Dec 17, 2025 the Commission proposed extending scope to downstream products with a high steel and aluminium content and making circumvention harder. The Council set out its position on Jun 12, 2026 and widened the scope further. Application is planned from Jan 1, 2028. This is a proposal in progress, not law — but anyone currently just below the de minimis threshold should follow it.
EU importers of covered goods — iron and steel, aluminium, cement, fertilisers, electricity, hydrogen. What matters is not company size but the good and the quantity: below 50 tonnes of net mass per calendar year, the obligations fall away entirely.
No. Since Jan 1, 2026 you need authorised declarant status and must record embedded emissions. Certificates only become available from Feb 1, 2027, and the first surrender is due by Sep 30, 2027 — retrospectively, for imports made in 2026.
It applies per importer per calendar year and is aggregated across all commodity codes. Stay below it and all CBAM obligations fall away; you declare this in the customs declaration. Exceed it during the year and the obligations apply to every good you imported that year. The threshold does not apply to electricity or hydrogen. The legal basis is Regulation (EU) 2025/2083.
The greenhouse gas emissions arising during production of the imported good. Direct emissions from the production process are covered; indirect emissions count only for cement and fertilisers. You can use actual producer data or fall back on default values.
No — these are often conflated. The CBAM simplification is its own Regulation (EU) 2025/2083 of Oct 17, 2025. Omnibus I is a directive and concerns the CSRD and CSDDD. Two different legal acts.
It has been proposed. The Commission tabled an extension to downstream products on Dec 17, 2025, the Council took its position on Jun 12, 2026, and application is planned from Jan 1, 2028. It is not yet adopted.
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