Carbon
CBAM & Decarbonization: Preparing Your Products for European Market Access
On 1 January 2026 the EU Carbon Border Adjustment Mechanism left its transitional reporting period. For covered goods, market access now depends on authorisation, emissions data and, in time, certificates.
What started in 2026
CBAM is set out in Regulation (EU) 2023/956 and was simplified before the definitive period by Regulation (EU) 2025/2083. From 1 January 2026, EU importers of covered goods — or their indirect customs representatives — who cross the threshold must hold the status of authorised CBAM declarant. Customs checks that status before release for free circulation.
Covered sectors are cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. A single mass-based threshold of 50 tonnes a year, counted across iron and steel, aluminium, fertilisers and cement, exempts smaller import flows. The threshold does not apply to electricity or hydrogen.
How the price is set
Authorised declarants buy CBAM certificates and surrender them against embedded emissions. In 2026 the certificate price follows the quarterly average auction price of EU ETS allowances. From 2027 it follows a weekly average. If a carbon price was already paid in the country of production, and that payment can be shown, the corresponding amount can be deducted.
Member States start selling certificates on the common central platform on 1 February 2027. A quarterly obligation to hold certificates covering 50 percent of emissions starts in 2027. Importers must still declare embedded emissions and surrender the matching certificates each year. Plan the data now; do not wait for the first purchase window.
What the exporter has to be able to hand over
Your EU customer cannot authorise themselves with a marketing brochure. They need the combined nomenclature code, the installation, the production period, and a defensible figure for embedded emissions. Actual data from the installation beats default values, which are the expensive fallback.
Keep the method, the underlying activity data, and any carbon price already paid in a form a customs representative can read. If several sites make the same product, do not average them into a single convenient number unless the rule you are relying on allows it.
Downstream goods are a separate file
In 2026 the Council supported extending CBAM to selected downstream products that contain large amounts of iron, steel or aluminium, together with new anti-circumvention measures. That was a negotiating position, not a finished regulation. Exporters of finished goods should watch the file. They should not redesign contracts around a text that has not been adopted.
Where this becomes a commercial term
EU buyers will push emissions data into supply contracts, next to price, Incoterms and origin. A supplier who can separate actual figures from estimates will be easier to keep. A supplier who cannot will be priced on defaults, or dropped from the bid.
We help exporters and their importers line up product scope, data quality and contract language before a shipment is the test.
General information as of October 2026, based on public texts including Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Not legal or tax advice. Certificate timing should be confirmed against the regulation and the national competent authority before a filing.