EU CBAM: who pays from 2026, the 50-tonne threshold, and what an exporter must provide

CBAM means Carbon Border Adjustment Mechanism. It puts on imported goods the carbon price an EU producer of the same goods pays under the EU Emissions Trading System (Art. 1(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 1, paragraph 1Click opens the article on EUR-Lex.). The duty sits with the EU importer, not with the foreign maker. This page is about the EU scheme; the UK runs its own CBAM from 1 January 2027 (GOV.UK).

What CBAM is and what changed on 1 January 2026

CBAM started on 1 October 2023 with a transitional period that ran until 31 December 2025. Importers then only reported emissions each quarter, and paid nothing (Art. 32Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 32Click opens the article on EUR-Lex.). Since 1 January 2026 the definitive period applies: importers of listed goods need an authorisation, declare the emissions embedded in their goods once a year, and surrender one CBAM certificate per tonne of CO2 equivalent (Art. 3(24)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 3, point 24Click opens the article on EUR-Lex., Art. 36(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 36, paragraph 2Click opens the article on EUR-Lex.).

Regulation (EU) 2025/2083 rewrote much of the scheme before it began. It entered into force on 20 October 2025 (Art. 2 of Regulation (EU) 2025/2083). It added the 50-tonne threshold, let a declarant hand the filing of its declaration to someone else, set 30 September as the yearly deadline, and set certificate sales to open on 1 February 2027 (Art. 2aRegulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2aClick opens the article on EUR-Lex., Art. 5(7a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 7aClick opens the article on EUR-Lex., Art. 6(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 6, paragraph 1Click opens the article on EUR-Lex., Art. 20(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 20, paragraph 1Click opens the article on EUR-Lex.).

Which goods the CBAM list covers

CBAM reaches only goods whose code is in its Annex I and which are released for free circulation in the EU (Art. 2(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2, paragraph 1Click opens the article on EUR-Lex., Art. 3(4)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 3, point 4Click opens the article on EUR-Lex.). A code with fewer than eight digits in the list covers every code that starts with it. The list as it stands on 6 October 2026:

The code alone decides. A product whose code is on the list is in scope even when it is partly made of other materials, and its whole net mass counts towards the threshold (Commission Q&A 4.30). Packaging is in scope only where the customs declaration gives the packaging its own listed code (Commission Q&A 1.12). Origin follows the EU non-preferential rules of origin (Art. 2(5)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2, paragraph 5Click opens the article on EUR-Lex.). Goods of UK, Chinese, Turkish, Indian or US origin are all in scope: only the countries and territories in Annex III are out. CBAM does not apply in Northern Ireland (Commission Q&A 7.12), but goods of Great Britain origin moved on from Northern Ireland into the EU are in scope (Commission Q&A 7.14).

CBAM threshold: 50 tonnes a year per importer

The threshold is 50 tonnes of net mass, per importer, per calendar year, counted across every listed code the importer brings in (Art. 2a(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2a, paragraph 1Click opens the article on EUR-Lex., Annex VII, point 1). It is not per shipment or per product.

• At or under 50 tonnes: the importer has no CBAM obligations for that year, including one that already holds the status of authorised CBAM declarant. It declares the exemption in each customs declaration (Art. 2a(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2a, paragraph 1Click opens the article on EUR-Lex.). The Commission names the TARIC document codes. Y137 is for an importer that does not expect to exceed 50 tonnes. From the moment it is foreseeable that the importer will, the code is Y128, with its CBAM account number (Commission Q&A 7.23). Y238 marks an application for the status that is still waiting for a decision (Commission Q&A 7.24).
• Over 50 tonnes: all obligations apply to all emissions in all goods imported that year, the first 50 tonnes included (Art. 2a(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2a, paragraph 2Click opens the article on EUR-Lex.).
• Hydrogen and electricity: no threshold; every importer needs the status (Art. 2a(4)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2a, paragraph 4Click opens the article on EUR-Lex.).

The threshold replaced the Regulation’s original exemption for consignments with an intrinsic value of EUR 150 or less, which Regulation (EU) 2025/2083 deleted. Low-value parcels of listed goods count towards the 50 tonnes like any other import.

Splitting imports to stay under the line does not work. An authority disregards an arrangement put in place mainly to fall below the threshold that has no valid commercial reason, and treats it as a serious infringement (Art. 25a(4)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 25a, paragraph 4Click opens the article on EUR-Lex.). The Commission watches import data and lists every importer past 90% of the threshold (Art. 25a(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 25a, paragraph 1Click opens the article on EUR-Lex.).

The Commission reviews the figure by 30 April each year. It changes it by delegated act only where the result moves by more than 15 tonnes, and a new figure applies from the next 1 January (Art. 2a(3)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2a, paragraph 3Click opens the article on EUR-Lex.). Its assessment published on 30 September 2026, for imports from 1 April 2025 to 31 March 2026, found that 50 tonnes exempts 0.87% of embedded emissions, under the 1% limit. No act changing the threshold had been published on 6 October 2026.

Who must be an authorised CBAM declarant

Only an authorised CBAM declarant may import listed goods, and customs refuse anyone else, apart from an importer within the threshold (Art. 4Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 4Click opens the article on EUR-Lex., Art. 25(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 25, paragraph 1Click opens the article on EUR-Lex.). Who holds the status:

The rows rest on Art. 5(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 1Click opens the article on EUR-Lex., Art. 5(1a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 1aClick opens the article on EUR-Lex., Art. 5(1b)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 1bClick opens the article on EUR-Lex. and Art. 5(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 2Click opens the article on EUR-Lex., and on the Commission’s Q&A 7.2 and 7.3. A representative acting as declarant carries the importer’s obligations for the goods it declares (Art. 5(2a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 2aClick opens the article on EUR-Lex.).

The applicant applies through the CBAM registry to the competent authority of the EU country where it is established, and needs an EORI number (Art. 5(3)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 3Click opens the article on EUR-Lex., Art. 17(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 17, paragraph 2Click opens the article on EUR-Lex.). The application gives its EORI number, a tax authority certificate that it has no outstanding recovery order for national tax debts, a declaration of honour on past infringements, proof of financial and operational capacity, and its estimated imports for this year and next (Art. 5(5)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 5Click opens the article on EUR-Lex.). An applicant not established throughout the two previous financial years must give a guarantee (Art. 17(5)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 17, paragraph 5Click opens the article on EUR-Lex.). The authority has 120 calendar days to decide. It may add 30 days where the applicant asks to adjust its application, and where it asks for more information the assessment takes at most 180 days (Article 2(4), Article 4(1) and Article 5(4) of Implementing Regulation (EU) 2025/486). Who needs the status, the application step by step and what customs do without it are on authorised CBAM declarant. Your number for customs is on EORI number.

An importer or representative that applied by 31 March 2026 could keep importing in 2026 while its application was pending. If the authority refuses, the goods imported since 1 January 2026 are priced on default values and penalised (Art. 17(7a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 17, paragraph 7aClick opens the article on EUR-Lex.). An application made after that date gives no such cover: the status must be granted before the threshold is crossed (recitals (10) and (11) of Regulation (EU) 2025/2083). An importer that applies expecting to go over and then stays under can have all the certificates it bought repurchased (Art. 23(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 23, paragraph 2Click opens the article on EUR-Lex.).

What a non-EU exporter must give its EU importer

The Regulation puts no duty on a producer or seller outside the EU unless it chooses to register its installation in the CBAM registry. The obligations and the penalties sit with the authorised CBAM declarant: the importer, or the indirect customs representative acting for it (Commission Q&A 1.16). Where you are yourself the importer from outside the EU, that is your indirect customs representative (Art. 5(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 2Click opens the article on EUR-Lex., Art. 5(2a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 5, paragraph 2aClick opens the article on EUR-Lex.). But the importer can pay on your actual emissions only if you supply them, verified. Otherwise it uses the Commission’s default values (Art. 7(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 7, paragraph 2Click opens the article on EUR-Lex., Art. 8(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 8, paragraph 1Click opens the article on EUR-Lex.). Those are set per country and per product, and raised by a mark-up: 10% for 2026, 20% for 2027 and 30% from 2028, and 1% for fertilisers (Article 1 and Annex I of Implementing Regulation (EU) 2025/2621; Annex I as replaced from 1 January 2026 by Implementing Regulation (EU) 2026/1740, with the same mark-ups). Your data is what keeps your goods from being priced at the top of the range.

What the importer needs from you, for each type of goods:

• the CN code, the quantity and the country of origin;
• the identity of the installation that made the goods, and the operator’s contact details;
• the specific embedded emissions per tonne, and the method used to calculate them;
• the verification report of an accredited verifier;
• where you paid a carbon price at home, the documents proving it, certified by a person independent of the importer and of your authorities, and proof of payment.

The list follows the importer’s record-keeping duty (Art. 7(5)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 7, paragraph 5Click opens the article on EUR-Lex., Annex V, points 1 and 2) and the carbon-price rule (Art. 9(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 9, paragraph 2Click opens the article on EUR-Lex.). The importer keeps these records until the end of the fourth year after the declaration (Art. 7(6)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 7, paragraph 6Click opens the article on EUR-Lex.).

If you run the installation, the emissions come from an operator’s emissions report and its summary, in English, with at least the content of the templates in the methodology act (Article 10 of Implementing Regulation (EU) 2025/2547). The Commission’s Excel communication template is recommended, not compulsory (Commission Q&A 1.15). The report must be verified by a verifier accredited by a national accreditation body in the EU (Art. 8(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 8, paragraph 1Click opens the article on EUR-Lex., Art. 10(5)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 10, paragraph 5Click opens the article on EUR-Lex.). If you trade goods made by someone else, pass on the producer’s data: only the installation that did the last processing can give it (Commission Q&A 7.22, 5.11).

You can register your installation in the CBAM registry and share verified data from there with every importer that buys from you. Registration is optional, lasts five years, and needs your name, address, registration number, the installation’s address and coordinates to six decimals, and its main activity (Art. 10(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 10, paragraph 1Click opens the article on EUR-Lex., Art. 10(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 10, paragraph 2Click opens the article on EUR-Lex., Art. 10(3)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 10, paragraph 3Click opens the article on EUR-Lex., Art. 10(7)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 10, paragraph 7Click opens the article on EUR-Lex.). The importer may then use your registered, verified figures (Art. 8(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 8, paragraph 2Click opens the article on EUR-Lex.). The registry publishes the operator’s name and the installation’s location unless you opt out (Art. 14(4)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 14, paragraph 4Click opens the article on EUR-Lex.). Verifiers could register in the CBAM registry from 1 September 2026 (Art. 10a(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 10a, paragraph 1Click opens the article on EUR-Lex.), and the Commission expects the first verification reports in early 2027 (Commission Q&A 5.11). Its guidance for operators sets the reporting period as the calendar year the goods were produced, not before 2026; where that cannot be shown, goods imported in 2026 take 2026 (Guidance document 2, section 3).

What the importer pays, and when

Certificates are sold on a common central platform from 1 February 2027, by the EU country where the declarant is established (Art. 20(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 20, paragraph 1Click opens the article on EUR-Lex.). For 2026 imports, the price is the average closing price of EU emissions allowances in the quarter the goods were imported (Art. 21(1a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 21, paragraph 1aClick opens the article on EUR-Lex.); from 2027 it is a weekly average (Art. 21(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 21, paragraph 1Click opens the article on EUR-Lex.). The Commission published EUR 75.36 per certificate for the first quarter of 2026, EUR 75.28 for the second and EUR 82.32 for the third; the fourth-quarter price is due on 4 January 2027.

Certificates bought for 2026 can be resold to the state only in 2027, on a request made by 31 October, and any left are cancelled without compensation on 1 November 2027 (Art. 23(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 23, paragraph 1Click opens the article on EUR-Lex., Art. 23(2a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 23, paragraph 2aClick opens the article on EUR-Lex., Art. 24(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 24, paragraph 2Click opens the article on EUR-Lex.). The free allocation adjustment shrinks the bill while EU producers still get free allowances; the Commission says those end for CBAM sectors in 2034 (Commission Q&A 1.4).

What happens if you import without it

Customs do not release listed goods to anyone but an authorised CBAM declarant, unless the importer is within the threshold (Art. 25(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 25, paragraph 1Click opens the article on EUR-Lex.).

• A declarant that does not surrender enough certificates by 30 September pays, for each missing certificate, the EU Emissions Trading System excess emissions penalty: EUR 100 per tonne of CO2 equivalent, raised in line with the European index of consumer prices. Paying does not remove the duty to surrender (Art. 26(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 26, paragraph 1Click opens the article on EUR-Lex., Art. 26(3)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 26, paragraph 3Click opens the article on EUR-Lex.; Article 16(3) and 16(4) of Directive 2003/87/EC).
• Anyone else who brings listed goods in without meeting the Regulation pays three to five times that penalty per certificate not surrendered (Art. 26(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 26, paragraph 2Click opens the article on EUR-Lex.).
• An importer that crosses 50 tonnes without the status pays the same three-to-five-times penalty, on all the emissions in that year’s imports. The authority may go lower where the importer went over by 10% or less, but not below the penalty a declarant pays. Payment ends the duty to declare and surrender for those imports (Art. 26(2a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 26, paragraph 2aClick opens the article on EUR-Lex.).

The authority counts the missing certificates on the net mass imported and the default values, after the free allocation adjustment (Art. 26(4a)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 26, paragraph 4aClick opens the article on EUR-Lex.). Customs send the EORI number, the eight-digit CN code, the quantity and the origin of every listed import to the Commission, periodically and automatically (Art. 25(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 25, paragraph 2Click opens the article on EUR-Lex.). Splitting imports to stay under the threshold is named circumvention (Art. 27(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 27, paragraph 2Click opens the article on EUR-Lex., point (b)).

What you can set aside

The proposed extension to downstream goods

On 17 December 2025 the Commission proposed adding steel- and aluminium-intensive downstream goods to Annex I from 1 January 2028. Its list includes steel kitchen and household articles, nails, springs, washing machines, refrigerator-freezers, seats with metal frames and metal office furniture (Commission proposal COM(2025) 989 and its Annex I). It is a proposal, not law: no act amending Regulation (EU) 2023/956Regulation (EU) 2023/956, Carbon Border Adjustment MechanismThe whole regulationClick opens the law on the EU Publications Office. has been published in the Official Journal since Regulation (EU) 2025/2083. Until one is, the list above is the list.

What the law leaves open

• How a carbon price paid abroad is deducted. The Regulation allows the reduction and lets the Commission set the conversion rules and the evidence by implementing act (Art. 9(1)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 9, paragraph 1Click opens the article on EUR-Lex., Art. 9(4)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 9, paragraph 4Click opens the article on EUR-Lex., Art. 9(5)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 9, paragraph 5Click opens the article on EUR-Lex.). The Commission said in May 2026 that it would adopt that act in 2026 (Commission Q&A 1.5); none had been published on 6 October 2026. Meanwhile, keep the evidence the Regulation already requires: the price effectively paid, any rebate, and certification by an independent person named on the documents (Art. 9(2)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 9, paragraph 2Click opens the article on EUR-Lex.).
• Whether the threshold stays at 50 tonnes for 2027. The Commission’s 30 September 2026 assessment found it within the 1% limit, and it changes only by delegated act applying from the next 1 January (Art. 2a(3)Regulation (EU) 2023/956, Carbon Border Adjustment MechanismArticle 2a, paragraph 3Click opens the article on EUR-Lex.). Meanwhile, plan on 50 tonnes: it is the figure in Annex VII until an act replaces it.

The tax and customs rules beside CBAM are listed on sell into the EU.