EU Regulation · CBAM
CBAM: the bill for 2026 arrives in 2027.
You buy no certificates this year. You still generate the liability this year. The emissions data you collect between now and December determines what those certificates cost — and most importers are collecting it badly.
Status
In force
Legal status
In force. Regulation (EU) 2023/956, amended by Regulation (EU) 2025/2083, in force since 20 October 2025.
Phase
Definitive regime, running since 1 January 2026. The transitional reporting-only phase ran from October 2023 to December 2025.
Last reviewed
14 August 2026
Most recent change
Implementing acts published on 17 December 2025 clarified emissions reporting and verification rules for the definitive phase.
Scope
Who it affects
CBAM applies to importers bringing covered goods into the EU, and to their indirect customs representatives. Covered sectors: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity.
The 50-tonne exemption is the first question to answer
A single mass-based de minimis threshold now applies: if your total annual net mass of covered goods stays at or below 50 tonnes, you are fully exempt — no authorisation, no reporting, no certificates. This replaced the old €150 consignment-value exemption.
Two conditions attach to it
Hydrogen and electricity are excluded from the exemption and remain covered at any volume. And crossing the threshold at any point in the year pulls all of your imports into scope, not just the tonnes above 50 — so monitor cumulative mass, not once a year. The Commission estimates this exempts around 90% of importers while still covering roughly 99% of embedded emissions.
Timeline
When it applies
Oct 2023 – Dec 2025
Transitional phase: quarterly reporting, no financial obligation.
20 October 2025
Regulation (EU) 2025/2083 in force: de minimis threshold, deadline changes, streamlined verification.
1 January 2026
Definitive regime starts. Financial liability begins accruing on imports.
31 March 2026
Deadline for applications that allowed continued importing on a provisional basis while authorisation was processed.
1 February 2027
CBAM certificate sales open on the EU central platform.
30 September 2027
First annual CBAM declaration and certificate surrender, covering 2026 imports.
30 September, annually
Deadline thereafter.
From 2027
Quarterly requirement to hold certificates covering at least 50% of embedded emissions to date, reduced from the originally planned 80%.
Certificate prices for the 2026 compliance year will reflect the quarterly average of 2026 EU ETS allowance prices. Your cost is being set by the market right now, against emissions you are importing right now.
Action
What to do now
1
Confirm your authorised declarant status.
Only authorised CBAM declarants may import covered goods above the threshold. If your application is still in process, know exactly where it stands.
2
Monitor cumulative mass monthly.
Not annually. The threshold is cumulative and the consequence of crossing it is retroactive across all imports.
3
Get actual emissions data from your suppliers, not default values.
Default values are a fallback, and generally an expensive one. Every tonne of embedded emissions you cannot substantiate with supplier data is a tonne you pay for at a conservative estimate. Supplier engagement is the highest-return activity in CBAM right now, and it takes months.
4
Check whether a carbon price was already paid at origin.
Carbon prices paid in the country of production can be deducted, but only with accurate documentation and traceability. This is real money left on the table by importers who did not ask. From 2027 the Commission may publish default carbon prices for third countries, with the methodology, directly in the CBAM registry.
5
Line up an accredited verifier.
Verification capacity is finite and the first annual declaration is a common deadline for everyone. Late is expensive.
6
Budget for February 2027.
No certificates are bought in 2026, which makes it easy to under-provision. The first purchase lands in Q1 2027 and covers a full year of imports.
Recent changes
What changed, in plain terms
50-tonne de minimis
A mass-based 50-tonne threshold replaced the consignment-value test, removing most small importers entirely.
Certificate sales moved
Certificate sales moved from January 2026 to February 2027, so the financial obligation applies retroactively to 2026 imports.
Holding requirement 80% → 50%
The quarterly holding requirement fell from 80% to 50%, easing working capital pressure.
Deadline moved to 30 September
The annual declaration and surrender deadline moved to 30 September, from the original 31 May.
Watch your guidance vintage
Regulation (EU) 2025/2083 was adopted as part of the broader simplification agenda. If a document you rely on says 31 May, it is out of date.
Watch out
Common misreadings
“Nothing to pay in 2026, so nothing to do in 2026.”
The liability accrues on 2026 imports. The data you fail to collect this year becomes a default value you pay for next year.
“We’re under 50 tonnes, so CBAM doesn’t apply.”
Check whether any of your volume is hydrogen or electricity, and check your cumulative figure rather than a single shipment.
“Our supplier’s certificate is enough.”
Embedded emissions must be calculated under CBAM’s own boundary and calculation rules. Existing product carbon footprint data is a useful starting point, not a substitute.
“The deadline is 31 May 2027.”
It is 30 September 2027. This changed in October 2025.
Ability Hub
What you get from Ability Hub
Prompt library
For reviewing supplier submissions and cross-checking calculations in your own AI environment.
Scope and threshold tracker
Cumulative mass monitoring, with the hydrogen and electricity carve-outs built in.
Supplier emissions data request pack
What to ask a non-EU producer for, in CBAM’s boundaries, in language a plant manager can act on.
Default values vs. actual data calculator guide
What the gap costs you, so the business case for supplier engagement writes itself.
Carbon price deduction checklist
Documentation needed to claim a price already paid at origin.
Compliance calendar
Authorisation, quarterly holdings, declaration and surrender, in one view.
No consulting engagement, no software lock-in. Your team does the work with material that assumes they are competent and busy.
Get access to CBAM materials
FAQ
Frequently asked questions
When do I have to buy CBAM certificates?
Sales open on 1 February 2027 through the EU central platform. There are no certificate purchases in 2026, even though 2026 imports generate the liability.
What is the 50-tonne threshold?
Importers whose total annual net mass of covered goods stays at or below 50 tonnes are exempt from all CBAM obligations. Hydrogen and electricity are excluded from the exemption.
When is the first declaration due?
30 September 2027, covering imports made during 2026. The deadline was moved from the original 31 May.
How much of my emissions must be covered by certificates each quarter?
From 2027, at least 50% of embedded emissions to date at the end of each quarter, reduced from the originally planned 80%.
Can I deduct a carbon price paid in the country of production?
Yes, subject to accurate documentation and traceability of the declared emissions.
Sources
Sources
Primary texts: Regulation (EU) 2023/956 (CBAM) and Regulation (EU) 2025/2083 (of 8 October 2025, simplifying and strengthening the mechanism; in force 20 October 2025), EUR-Lex; Implementing Regulation (EU) 2025/486 on the status of authorised CBAM declarant. Commission resources: “Carbon Border Adjustment Mechanism” (DG TAXUD), including sectors, verification and certificate prices; the CBAM definitive regime pages; and the CBAM Registry. Announcements: “Officially published: simplifications for the CBAM”, 20 October 2025 — the 50-tonne threshold exempts around 182,000 importers while still covering over 99% of in-scope emissions; “CBAM successfully entered into force on 1 January 2026”, 14 January 2026.
Ability Hub is not a law firm and does not provide legal advice. This page describes the state of the law as reviewed on the date shown above.
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