CBAM in 2026: A Practical Guide for EU Importers

The EU Carbon Border Adjustment Mechanism, better known as CBAM, entered its definitive phase on 1 January 2026.

That means it has moved beyond the transitional reporting period and now carries financial as well as administrative obligations for businesses importing certain carbon-intensive goods into the European Union.

If your business imports products such as steel, aluminium, cement, fertilisers, hydrogen or electricity, CBAM may affect how you buy from overseas suppliers, manage customs data, calculate import costs and plan cash flow.

The rules can appear highly technical, particularly when discussions turn to embedded emissions, verification and CBAM certificates. But the basic idea is easier to understand: the EU wants the carbon cost attached to certain imported goods to be comparable with the carbon cost faced by producers inside the EU.

For importers, the key questions are straightforward. Are your goods covered? Do you cross the applicable threshold? Can your suppliers provide reliable emissions data? And have you prepared for the cost of purchasing CBAM certificates?

What CBAM is designed to achieve

EU producers in carbon-intensive industries are covered by the EU Emissions Trading System. This places a price on the greenhouse gas emissions associated with their production.

The concern is that companies could avoid this cost by moving production to countries with less demanding climate policies or replacing EU-made goods with more carbon-intensive imports. This is known as carbon leakage.

CBAM is intended to reduce that risk. It applies a carbon-related cost to certain goods imported into the EU, based on the emissions generated during their production.

The European Commission’s CBAM guidance explains that the mechanism complements the EU Emissions Trading System and is intended to encourage cleaner industrial production outside Europe as well as within it.

CBAM isn’t a conventional customs duty calculated as a percentage of a product’s value. The potential cost is linked to embedded emissions and the price of EU Emissions Trading System allowances.

Which sectors are currently covered?

CBAM currently applies to selected goods in six carbon-intensive sectors:

• Cement
• Iron and steel
• Aluminium
• Fertilisers
• Electricity
• Hydrogen

That list sounds simple, but the real test takes place at product level. Not every product containing steel or aluminium is automatically covered. The customs classification of the imported goods is what determines whether they fall within CBAM’s scope.

For example, an importer may describe a product commercially as a “metal component,” “construction fitting” or “industrial part.” Those descriptions may work perfectly well on a website or purchase order, but they don’t tell you whether the product falls under a commodity code covered by CBAM.

This is why importers need to work from the actual customs code rather than the product’s everyday name.

Start with commodity codes, not assumptions

The first practical step is to compare the commodity codes used in your customs declarations with the codes covered by the CBAM legislation.

Here’s the catch: product classification can change when the material, design, manufacturing process or intended use changes. A code provided by a supplier several years ago may no longer be correct for the product being imported today.

Businesses should check whether the same code is being used consistently across:

• Supplier invoices
• Purchase orders
• Customs declarations
• Freight-forwarder records
• Product databases
• Accounting and inventory systems

If different systems show different codes for the same product, that’s a warning sign. It could mean that CBAM exposure is being missed or that the business is treating goods as covered when they are actually outside the scope.

Where classification is uncertain, importers should seek specialist customs advice. Guessing the code or copying it from a competitor’s website can create customs, tax and CBAM problems at the same time.

The 50-tonne threshold explained

Under the definitive regime, EU importers and indirect customs representatives generally need authorised CBAM declarant status when they import more than 50 tonnes of covered CBAM goods into the EU.

This is a single mass-based threshold. Businesses should look at their total relevant import activity rather than judging each shipment in isolation.

An importer might receive only a few tonnes at a time and assume that CBAM isn’t a concern. But if those shipments push the annual total above 50 tonnes, the authorisation and compliance requirements can become relevant.

The threshold applies to the covered CBAM goods specified by the rules, and sector-specific treatment may need to be considered. Businesses importing close to the threshold should monitor volumes throughout the year instead of waiting until year-end.

A basic monitoring report should show:

• Commodity code
• Product description
• Net mass
• Country of origin
• Supplier
• Date of import
• Customs declaration reference
• Importing legal entity
• Running annual total

This doesn’t need to begin as an elaborate technology project. A reliable report built from accurate customs data is far more useful than a complex dashboard based on inconsistent product information.

Becoming an authorised CBAM declarant

Importers that exceed the threshold generally need to apply for authorised CBAM declarant status. An indirect customs representative may take on this role in certain arrangements, but the responsibilities should be made clear in writing.

Authorisation gives the declarant access to the CBAM system and allows it to purchase and surrender certificates.

Businesses shouldn’t assume that their customs broker will automatically take responsibility. A broker may submit customs declarations without agreeing to become the authorised CBAM declarant or take responsibility for emissions data.

Importers should confirm:

• Who will hold the authorised declarant status
• Who will access the CBAM Registry
• Who will collect supplier emissions data
• Who will prepare the annual declaration
• Who will purchase and surrender certificates
• Who will deal with corrections or authority queries
• Who bears the cost if the data is incomplete or inaccurate

These points should be reflected in contracts with customs representatives, suppliers and logistics partners.

Why supplier emissions data matters

Once you know that a product is covered, the next challenge is calculating the emissions embedded in it.

Embedded emissions are the greenhouse gas emissions associated with producing the imported goods. Depending on the product and applicable methodology, the calculation may involve direct emissions from the production process and certain indirect emissions.

The importer often depends on the overseas manufacturer for this information. That can be difficult when the supplier has never measured emissions in the format CBAM requires.

A supplier may provide a sustainability report or a carbon footprint for the business as a whole. That information may be useful, but it doesn’t necessarily show the installation-level or product-specific data required for CBAM.

Importers should ask suppliers:

• Where was the product manufactured?
• Which installation produced it?
• What production method was used?
• Which emissions are included in the calculation?
• Which reporting methodology was followed?
• What reporting period does the data cover?
• Is supporting evidence available?
• Has the information been independently verified where required?

A precise-looking emissions figure isn’t automatically reliable. The importer needs to understand how the number was produced and whether it matches the applicable methodology.

Actual emissions versus default values

Where reliable actual emissions data isn’t available, the CBAM framework may require or permit the use of prescribed default values, depending on the applicable rules.

Default values can help businesses complete a calculation when supplier information is missing. But they shouldn’t be treated as the easiest long-term option.

A default value may be less favourable than the supplier’s actual performance, particularly where the manufacturer uses cleaner energy or more efficient production methods. Relying on defaults could therefore increase the number of CBAM certificates required.

Importers should compare the cost and effort of collecting actual data with the potential financial impact of using defaults.

The Commission publishes CBAM default values and technical guidance for the definitive period. Businesses should make sure they use the correct version for the relevant product and reporting year.

How CBAM certificates work

Authorised CBAM declarants must purchase certificates corresponding to the embedded emissions of covered imports.

The price of a CBAM certificate is linked to the auction price of allowances under the EU Emissions Trading System. In 2026, the certificate price is calculated using a quarterly average. From 2027, the calculation moves to a weekly average.

This means the cost isn’t fixed. It can change as EU carbon prices move.

Importers should consider CBAM in their budgets, product costing and pricing decisions. Waiting until certificates must be surrendered may result in an unexpected cash-flow requirement.

A useful forecast should consider:

• Expected import volumes
• Product mix
• Supplier emissions intensity
• Use of actual or default values
• Expected certificate prices
• Carbon prices already paid outside the EU
• Changes in sourcing during the year

Corpera’s accounting services can help businesses connect import records, supplier information and CBAM-related costs with their financial reporting and management accounts.

What if a carbon price was already paid abroad?

If the importer can prove that a carbon price was paid in the country where the goods were produced, the corresponding amount may be deducted from the CBAM obligation.

But evidence matters. A general environmental levy or energy charge may not necessarily qualify as a carbon price for this purpose.

The importer should obtain records showing:

• The type of carbon price paid
• The amount paid
• The emissions to which it relates
• The period covered
• The party that made the payment
• Whether any rebate or compensation was received
• How the amount connects to the imported goods

This information can be difficult to reconstruct after the goods have entered the EU. It’s better to build the requirement into supplier communications and purchasing contracts from the start.

Verification and the annual CBAM declaration

The definitive regime requires importers to declare the embedded emissions associated with covered imports and surrender the corresponding number of certificates.

Emissions data may also need to be verified under the applicable CBAM verification rules. This adds another reason to collect information in a structured and traceable way.

The reporting process should connect:

1. The original purchase order
2. The supplier and production installation
3. The customs declaration
4. The commodity code and imported mass
5. The emissions calculation
6. Supporting evidence
7. Verification records
8. The annual CBAM declaration
9. The certificates purchased and surrendered

If those records sit in different systems, the business needs a clear method for reconciling them.

The CBAM Registry supports declarations, certificate management and compliance monitoring. Access is obtained through the relevant national competent authority in the importer’s EU country of establishment.

CBAM should influence purchasing decisions

CBAM isn’t only a compliance exercise for the tax or sustainability team. It can change the true cost of buying from a particular supplier.

Two manufacturers may quote the same price for the same product, but the supplier with higher embedded emissions could create a larger CBAM cost.

Procurement teams should begin considering:

• Product price
• Transport cost
• Import duties
• Embedded emissions
• Expected certificate cost
• Reliability of supplier data
• Verification support
• Production method
• Energy source
• Delivery risk

This gives management a more complete view of the landed cost.

Businesses may decide to work with lower-emission suppliers, renegotiate contracts or source some goods within the EU. These decisions should be based on proper financial and operational analysis rather than the certificate cost alone.

Corpera’s business advisory services can support businesses in assessing how regulatory costs affect sourcing, pricing and cross-border operations.

Common CBAM mistakes to avoid

Several mistakes can create unnecessary cost or compliance risk:

• Assuming every product containing steel or aluminium is covered
• Relying on commercial product names instead of customs codes
• Looking at individual shipments rather than annual import volumes
• Assuming the customs broker is responsible for CBAM
• Asking suppliers for emissions data too late
• Accepting emissions figures without understanding the methodology
• Using outdated default values
• Failing to document carbon prices paid abroad
• Treating CBAM as a sustainability issue with no accounting impact
• Waiting until the annual declaration to reconcile customs data

The best time to identify these issues is before import volumes and certificate costs become difficult to manage.

A practical CBAM action plan for 2026

Importers should take the following steps:

1. Extract all 2026 import data for potentially covered goods.
2. Review commodity codes against the current CBAM scope.
3. Calculate cumulative net mass against the 50-tonne threshold.
4. Confirm which entity acts as importer and authorised declarant.
5. Review responsibilities with customs representatives.
6. Identify the overseas installation producing each covered good.
7. Request emissions data and supporting evidence from suppliers.
8. Document whether actual or default values will be used.
9. Assess whether a qualifying carbon price was paid abroad.
10. Forecast certificate requirements and cash-flow exposure.
11. Reconcile customs, emissions and accounting data.
12. Prepare the annual declaration and verification process.
13. Monitor updated Commission guidance and certificate prices.

Corpera’s Tax and VAT services can help businesses assess CBAM exposure, organise supporting records and connect the new requirements with their wider tax and accounting processes.

Businesses that import covered products or need help understanding their reporting position can contact Corpera to discuss their circumstances.

CBAM is manageable when the work begins with the right data. Start with customs codes and import volumes, then move to supplier emissions, verification and certificate planning. Breaking the process into those steps makes a technical regulation far easier to handle.

This article is provided for general information and does not constitute personalised tax, customs, environmental, legal or regulatory advice.

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