CBAM Definitive Regime 2026: What EU Importers Must Do Now
Published 18 Revisado / June 2026 · IgeraSolutions Editorial Team · 12 min read
The Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase on 1 January 2026. After a transitional period of reporting-only obligations (October 2023 – December 2025), importers of covered goods into the EU must now purchase and surrender CBAM certificates to cover the embedded carbon content of their imports. Failure to comply triggers penalties of up to three times the certificate price. This guide explains every obligation, deadline and practical step EU importers need to take right now.
Key date
The first CBAM annual declaration covering calendar year 2026 imports is due by 31 May 2027. Certificates must be surrendered by the same date. However, importer registration in the CBAM Registry is required before the first import, and quarterly carbon reporting obligations apply throughout the year.
Which goods are covered by CBAM?
| Sector | Key CN codes | Scope |
|---|---|---|
| Cement | CN 2523, 6810, 6811 | Clinker, grey cement, white cement |
| Steel and iron | CN 72–73 (selected) | Pig iron, crude steel, bars, rods, pipes |
| Aluminium | CN 7601, 7603–7616 | Unwrought, bars, profiles, wire |
| Fertilisers | CN 3102–3105 | Urea, ammonium nitrate, mixed NPK |
| Hydrogen | CN 2804 10 | Grey and blue hydrogen |
| Electricity | CN 2716 | Cross-border electricity imports |
5-step CBAM compliance process
Register as an Authorised CBAM Declarant
Register in the EU CBAM Registry (managed by each Member State's national authority — AEAT in Spain, HMRC analogue via DEFRA in UK-equivalent context). You need your EORI number, VAT registration and a designated responsible person. Registration takes 2–6 weeks; do not wait until December 2026 to start.
Obtain embedded carbon data from your supplier
You must report the actual embedded carbon (Scope 1 direct emissions + Scope 2 indirect emissions for power-intensive sectors) of each product imported. Non-EU suppliers must calculate this using the CBAM calculation methodology (Implementing Regulation EU 2023/1773). If the supplier cannot provide actual data, you must use CBAM default values — which are set deliberately high to discourage reliance on defaults.
Purchase CBAM certificates
CBAM certificates are priced weekly by the European Commission, linked to the average EU ETS allowance price from the previous week. In 2026, ETS prices have ranged between €55 and €72 per tonne CO2. You buy certificates through the CBAM Registry at the current weekly price. You can hold up to the quantity needed for the current calendar year plus the next two years.
Submit the annual CBAM declaration
By 31 May 2027 (for 2026 imports), submit a declaration in the CBAM Registry covering: total quantity imported per goods category, total embedded carbon, country of origin, production facility, and carbon price already paid in the country of origin (which can offset CBAM costs). The declaration must be verified by an accredited third-party verifier if annual embedded carbon exceeds certain thresholds.
Surrender certificates equal to embedded carbon
On 31 May 2027, surrender CBAM certificates equal to the total embedded carbon tonnes declared. Unsurrendered obligations attract the penalty of three times the prevailing certificate price plus an obligation to surrender the deficit in the following period. Excess certificates may be repurchased by the Commission at the purchase price.
Penalty structure
Under Article 26 of Regulation (EU) 2023/956, failure to surrender sufficient CBAM certificates results in a penalty of 3x the average CBAM certificate price during the calendar year, applied per tonne CO2 equivalent not covered. At 2026 ETS prices of €65/t, this means up to €195 per tonne shortfall — on top of still having to surrender the certificates.