CBAM basics

From 1 January 2026, importers must be authorised CBAM declarants to import CBAM goods into the EU customs territory. To obtain this status, you apply to the national competent authority of the Member State where you are established. Importers of CBAM goods other than hydrogen and electricity that stay below the annual mass-based threshold of 50 tonnes do not need an authorisation; importers of hydrogen and electricity always do. Authorised declarants above the threshold must, by 30 September of the year following importation (first time 30 September 2027 for the 2026 import year), submit an annual CBAM declaration of the embedded emissions of the goods they imported and surrender the corresponding number of CBAM certificates. From 2027, they must also hold, at the end of each quarter, certificates covering at least 50% of the emissions embedded in goods imported since the start of the year.

The Carbon Border Adjustment Mechanism mirrors and complements the EU Emissions Trading System (ETS). It puts a price on the greenhouse gas emissions embedded in selected goods imported into the EU, at a level equivalent to what EU producers pay under the ETS. Importers declare the embedded emissions of the goods they imported in a given year and surrender a matching number of CBAM certificates. That number is reduced by two elements: the free allocation adjustment (mirroring the free allowances EU producers receive under the ETS) and any carbon price already effectively paid in the country of origin. CBAM currently applies to iron and steel, cement, fertilisers, aluminium, hydrogen and electricity — sectors at high risk of carbon leakage.

The EU ETS caps emissions from power generation and heavy industry, and distributes a shrinking number of free allowances to prevent carbon leakage. As those free allowances are phased out for CBAM sectors between 2026 and 2034, the CBAM is phased in to match. Until free allowances in CBAM sectors are fully removed in 2034, CBAM applies only to the share of emissions that would not have received free allowances under the ETS — so importers are treated even-handedly with EU producers. The price of a CBAM certificate mirrors the EU ETS allowance price.

CBAM applies to imports of goods in six sectors: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. These were chosen for their high risk of carbon leakage and high emission intensity — together they represent more than half of the emissions of the sectors covered by the EU ETS. Whether a specific product is in scope is determined by its CN (Combined Nomenclature) code as listed in Annex I to the CBAM Regulation. The mechanism may be extended to further ETS sectors in the future.

The CBAM declarant is either the importer or the indirect customs representative, depending on who enters the CBAM account number in the customs declaration. The importer is responsible when it lodges the customs declaration for release for free circulation in its own name and on its own behalf. An indirect customs representative is responsible when it lodges the declaration — mandatory where the importer is established outside the EU, and possible by agreement where the importer is established inside the EU. Liability for an incorrect or incomplete declaration lies with the authorised declarant.

An EORI (Economic Operators Registration and Identification) number is a unique identifier assigned by a customs authority to an economic operator across the entire EU customs territory. There is only one EORI number per operator, and it is used for all customs activities in any Member State. Authorised CBAM declarants must submit their annual CBAM declaration using the same EORI number they provided to customs when importing. The EORI number does not, however, determine which national competent authority is responsible — that is always the Member State where the declarant is established.