CBAM for Steel and Cement Importers 2026: Declarations, Carbon Prices and Compliance Guide
Igera RegTech Team · Updated Revisado / June 2026 · 12 min read
The Carbon Border Adjustment Mechanism (CBAM, Regulation EU 2023/956) entered its definitive regime on 1 January 2026. Steel and cement importers now face binding annual declarations, carbon price payments and the risk of losing their authorised declarant status if they fail to comply. With EU ETS prices hovering around €62 per tonne, the financial stakes are significant — yet many mid-sized importers still lack the regulatory infrastructure to manage CBAM obligations.
CBAM — Definition: The Carbon Border Adjustment Mechanism (Regulation EU 2023/956) is an EU trade and climate policy instrument that places a carbon price on imports of goods from outside the EU when those goods are produced using processes that emit significant greenhouse gases. It applies to six sectors: steel, cement, aluminium, fertilisers, electricity and hydrogen. The transitional phase (quarterly reporting, no payment) ran from 1 October 2023 to 31 December 2025. The definitive regime (annual declarations + CBAM certificate purchases) started on 1 January 2026.
63%
of all CBAM declarations expected in the definitive regime will come from steel and cement importers alone, according to the European Commission's impact assessment (SWD 2023/177). Steel (HS chapter 72) and cement (HS 2523) together represent the highest embedded emission volumes and the most complex calculation methodologies under the CBAM Implementing Regulation.
— European Commission CBAM Impact Assessment SWD 2023/177
From transitional to definitive: what changed on 1 January 2026?
During the transitional phase (Q4 2023–Q4 2025), importers were required only to submit quarterly embedded emissions reports — no payment was due. That phase ended on 31 December 2025. From 1 January 2026, the definitive CBAM regime imposes three binding obligations:
1. Authorised CBAM Declarant status
From 1 January 2026, only authorised CBAM declarants (registered with the national competent authority — HMRC in the UK for UK-based importers into the EU, AEAT in Spain, HMRC for UK imports) may import CBAM goods into the EU. The application window opened in 2025. Importers who missed the deadline or whose application was rejected may not import CBAM goods until authorisation is granted.
2. CBAM certificates: purchase and surrender
CBAM certificates must be purchased from the national registry at a price tied to the weekly average EU ETS allowance price. By 31 May of each year, declarants must surrender a number of CBAM certificates equal to the verified embedded emissions in the goods imported during the prior calendar year. Certificates not surrendered may be repurchased by the national authority at a loss. Unused certificates (up to one-third of the total purchased) may be resold.
3. Annual CBAM declaration
By 31 May each year, the authorised declarant must submit a CBAM declaration covering all imports of CBAM goods during the prior year. The declaration must include: total quantity of goods (in tonnes), country of origin, embedded emissions (verified by an accredited CBAM verifier where required), any carbon price already paid in the country of origin, and the corresponding CBAM certificate surrender. The European Commission CBAM registry hosts the submission portal.
Steel vs Cement under CBAM: declaration fields, embedded emissions and grey areas
| Parameter | Steel (HS 72xx) | Cement (HS 2523) |
|---|---|---|
| CN codes in Annex I | 7201–7229 (pig iron, ferro-alloys, flat/long products, tubes), plus certain downstream goods in Annex II | 2523 10 00 (cement clinker), 2523 29 00 (Portland cement), 2523 90 10 (aluminous cement) |
| Embedded emission type | Direct (Scope 1) + indirect electricity emissions (Scope 2) for EAF route; direct only for BOF route | Direct (calcination CO₂) dominates — typically 60–65% of total clinker emissions |
| Default emission values | Available per production route (BOF: ~2.1 tCO₂/t; EAF: ~0.4 tCO₂/t); country-specific defaults in Commission Implementing Regulation | ~0.83 tCO₂/t clinker (global average); country defaults available from Commission registry |
| Key declaration fields | Production route (BOF/EAF/DRI), facility ID, scrap ratio (EAF), electricity source and emission factor (if indirect included) | Clinker-to-cement ratio, kiln fuel type, alternative fuel share, calcination conversion factor |
| Grey area / risk | Mixed-origin scrap in EAF: determining the country of origin of the finished product when scrap sourced globally | Blended cements (e.g. Portland-pozzolana): determining clinker share and applicable CN code |
| Carbon price offset (art. 9 CBAM Reg) | Credit available if exporting country has explicit carbon price on production (e.g. UK ETS, South Korea ETS). Must be documented with verifier confirmation | Same credit mechanism; fewer major cement exporters have compliant carbon pricing — China ETS covers power sector only |
Your compliance team has CBAM questions every week?
IgeraRegTech has Regulation EU 2023/956, the CBAM Implementing Regulation, European Commission FAQs and ETS guidance indexed. Ask any CBAM question — commodity code coverage, embedded emission methodology, carbon price offsets — and get the exact article reference in under 3 seconds.
Try IgeraRegTech — freeSet up in under 24 hours · CBAM Regulation updated June 2026