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.
Case study: German steel importer reduces CBAM costs by 28%
A German automotive parts manufacturer importing 8,400 tonnes of hot-rolled steel coil from Turkey annually faced a potential CBAM liability of €3.1 million using default carbon values (Turkish steel industry average: 1.8 t CO2/t steel × €65/t × 8,400 t = €983,000 before any offset).
Working with IgeraRegTech, the company supported its Turkish supplier in implementing continuous emission monitoring at the rolling mill. Actual embedded carbon was 1.29 t CO2/t steel — 28% below the default value. Using actual data instead of defaults reduced the annual CBAM certificate purchase cost from €983,000 to €707,000, saving €276,000 per year.
Additionally, Turkey has a national carbon pricing mechanism. The carbon price paid by the Turkish producer (€18/t CO2) qualified for an offset under Art. 9 of the CBAM Regulation, reducing the net CBAM payment further by €194,000. Total saving vs. default approach: €470,000/year.
For more information and a reference guide about this vertical, visit our Igera pillar page.
Frequently asked questions
Does CBAM apply to imports from countries with their own carbon pricing (ETS)?
Yes, but importers can deduct the carbon price actually paid in the country of origin. If a country has a linked ETS with prices equivalent to EU ETS, the net CBAM payment is zero or minimal. This currently applies to goods from Iceland, Liechtenstein and Norway (EEA). Switzerland has a linked ETS. UK ETS and EU ETS are not currently linked, so UK goods are subject to CBAM.
Who is responsible for CBAM compliance — the importer or the customs agent?
The legal obligation rests entirely on the Authorised CBAM Declarant — typically the EU importer or the entity named on the customs declaration. Customs agents can file on behalf of importers but cannot be the declarant unless the import is in their name. Liability cannot be contractually transferred to suppliers or freight forwarders.
Is CBAM applicable to goods imported under inward processing relief?
Goods placed under inward processing (IP) are not subject to CBAM during the IP period. However, if goods are released for free circulation at the end of the IP procedure, CBAM obligations arise at that point based on the embedded carbon of the original imported goods.
When will CBAM expand beyond the current 6 sectors?
The European Commission is required to review CBAM scope by 2026. The review is expected to propose extending CBAM to organic chemicals, plastics, glass and paper by 2030, aligned with the full phase-out of free ETS allowances to EU producers. No formal legislative proposal had been published as of June 2026.
How does IgeraRegTech help with regulatory compliance?
IgeraRegTech indexes complex regulations like DORA, NIS2, or the AI Act and answers compliance questions in seconds, citing the exact article and paragraph of the legal text.
Does the system hallucinate or invent regulatory articles?
No. Thanks to the RAG architecture, IgeraRegTech only answers based on the official texts of the directives and regulations loaded into the knowledge base.
Automate your CBAM compliance with IgeraRegTech
From supplier carbon data collection to certificate management and annual declaration filing — IgeraRegTech handles the full CBAM workflow, integrated with your ERP and customs systems.
Explore IgeraRegTechReviewed by: IgeraSolutions Compliance Team