CBAM regulation: how it works, the 50 tonne threshold, certificates and deadlines for importers

FRIDAY, 6 NOVEMBER 2026

Which goods are covered, when the 50 tonne threshold is exceeded, what the authorised declarant does, what certificates cost in 2026 and when to declare, with an example on 80 tonnes of profiles.

The CBAM regulation, in one line: whoever imports iron, steel, aluminium, cement, fertilisers, hydrogen or electricity into the EU pays for the carbon emitted to make them, by buying certificates tied to the European CO2 price. Since 1 January 2026 the mechanism is in its definitive phase, but an importer staying under 50 tonnes a year is outside it.

CBAM regulation: the basic idea

The CBAM (Carbon Border Adjustment Mechanism) was set up by Regulation (EU) 2023/956. Its aim is to put producers in Europe, where plants pay for emissions under the ETS, on the same footing as producers outside. From 2023 to 2025 there was a transitional phase made only of quarterly emission reports. From 2026 the emissions contained in imported goods, called embedded emissions, carry a cost.

Regulation (EU) 2025/2083 of 8 October 2025, published on 17 October, simplified the rules before the start: it introduced the 50 tonne threshold, moved certificate sales and the first declaration to 2027, and lowered the share to be held each quarter. This guide follows the rules as they stand after that amendment.

Which goods are covered

The CBAM covers six sectors: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. The exact items are listed by Combined Nomenclature code in Annex I of the regulation, and they include several derived metal products, not only raw materials. The check is therefore made on the customs code of the goods, not on their trade name.

For those buying finished articles in China or Asia the point is this: a product may contain steel or aluminium without falling under the CBAM, if its code is not in Annex I. Conversely, semi-finished goods such as bars, profiles, sheets, tubes or some metal articles may be covered. The check has to be made item by item, before the order.

The 50 tonne threshold

The threshold is a single one and is measured in net mass: if in a calendar year an importer brings 50 tonnes or less of CBAM goods into the EU in total, the obligations do not apply. The count is cumulative per importer and adds up all sectors, except electricity and hydrogen, which do not benefit from the exemption.

An importer exceeding 50 tonnes does not pay only on the excess: the obligations apply to all CBAM imports of that year, from the first tonne. Since 1 January 2026 the exemption has to be stated in the customs declaration. For a company importing a few lots of profiles or small metal parts, the count must therefore be kept up to date during the year, not in December.

The authorised CBAM declarant

Above the threshold, goods can only be imported with the status of authorised CBAM declarant, applied for in the CBAM registry. To avoid blocking imports in early 2026, those who applied by 31 March 2026 could keep importing while awaiting the decision, which the competent authority must take by 27 September 2026.

Those who have not applied and expect to exceed 50 tonnes must do so before the shipment that would take them over the limit. The status can also be requested by an indirect customs representative, who in that case answers for the CBAM obligations together with the customs formalities.

CBAM certificates: price and purchase

Each certificate covers one tonne of CO2 equivalent embedded in the goods. The price is the weighted average of ETS allowance auction prices. For 2026 the Commission publishes one price per quarter:

• first quarter 2026: 75.36 euro per certificate, published on 7 April 2026;
• second quarter 2026: 75.28 euro, published on 6 July 2026;
• third quarter 2026: 82.32 euro, published on 5 October 2026;
• fourth quarter 2026: publication scheduled for 4 January 2027;
• from 2027: a weekly price.

Certificates for 2026 imports cannot be bought straight away: sales on the common European platform start on 1 February 2027. From 2027, at the end of each quarter the declarant must hold certificates equal to at least 50% of the emissions embedded in goods imported since the start of the year (it was 80% before the amendment). Certificates bought in excess can be sold back to the Commission within limits and deadlines set by the regulation.

The annual declaration and penalties

Each year the declarant files the CBAM declaration with the quantities imported and the embedded emissions, checked by an accredited verifier when actual plant data are used. The first one, on 2026 imports, is due on 30 September 2027; the deadline stays at 30 September of the following year for later years too. The matching number of certificates is surrendered with the declaration.

The carbon price already paid in the country of origin, if documented, and the share reflecting the free allowances still given to European industry can be deducted from the bill. Penalties are heavy: for each certificate not surrendered the ETS penalty of 100 euro per tonne of emissions applies, and importing above the threshold without authorisation risks three to five times that amount.

An example with numbers

Hypothetical example. An Italian company imports 80 tonnes of aluminium profiles from China in 2026 under an Annex I code. It exceeds the 50 tonne threshold, so all 80 tonnes are subject to the obligations, not just the extra 30. If the embedded emissions declared by the producer were 8 tonnes of CO2 per tonne of product, the total would be 640 tonnes of CO2.

At a price close to the third quarter 2026 one, about 80 euro, the gross cost would be around 51,200 euro, less any carbon price paid in China and the adjustment for free allowances. That is about 640 euro per tonne of product: enough to change the comparison between two suppliers. If the same company stopped at 45 tonnes in the year, it would have no CBAM obligations.

What to ask the supplier

The figure that sets the cost is the embedded emission, and only the producer knows it. Without actual data the default values published by the Commission are used, which usually lead to a higher bill. Four things should be asked of the supplier: the exact customs code of the goods, the plant where the metal was produced, the emissions per tonne calculated with the EU method, and any carbon price paid in its country.

It is worth writing these requests into the contract, together with a commitment to provide the data in time for verification. A supplier who cannot answer today is unlikely to do so in September 2027, when the declaration is due.

Deadlines at a glance

The calendar after the simplification is this: from 1 January 2026 definitive phase and 50 tonne threshold to be stated at customs; 31 March 2026 deadline to apply as authorised declarant with imports allowed in the meantime; 1 February 2027 opening of certificate sales; from 2027 quarterly coverage of 50%; 30 September 2027 first annual declaration and surrender of certificates for 2026.

With La Merce, understanding how the CBAM regulation works means knowing before the order whether the profiles fall under Annex I, how many tonnes are left before the 50 tonne threshold and which emission data to ask the factory for, while the supplier can still be chosen.

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