Short answer: CBAM is the EU's Carbon Border Adjustment Mechanism. It requires certificates for the production emissions of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen imported into the EU. The liable party is the importer in the EU. What it needs from a producer outside the EU is emissions data.
If your EU buyer asks you for "CBAM data", the reason is simple: the buyer files the declaration, but the number is created in your installation. This article follows the text of Regulation (EU) 2023/956, with article numbers. The information was read from the sources on 13 October 2026.
What is CBAM and what does it stand for?
CBAM stands for Carbon Border Adjustment Mechanism. In Türkiye it is known as SKDM, the Turkish abbreviation of the same name.
The mechanism addresses the greenhouse gas emissions embedded in the goods listed in Annex I when they are imported into the customs territory of the Union, to prevent the risk of carbon leakage (2023/956 Art. 1(1)). It complements the EU Emissions Trading System by applying an equivalent set of rules to imports (Art. 1(2)).
The unit is the certificate. One CBAM certificate corresponds to one tonne of CO2e of emissions embedded in goods (Art. 3(24)).
Who is liable under CBAM?
The obligation sits on the EU side. Goods in scope may be imported only by an "authorised CBAM declarant" (Art. 4). An importer established in a Member State applies for that status before importing (Art. 5(1)). Where the importer is not established in a Member State, the indirect customs representative obtains the status (Art. 5(2)).
Each year the authorised declarant:
- submits a CBAM declaration for the preceding calendar year, with the quantity imported, the total embedded emissions and the number of certificates to be surrendered (Art. 6(1), 6(2));
- surrenders the number of certificates that corresponds to the declared emissions (Art. 22(1));
- keeps the records used for the calculation until the end of the fourth year after the year of the declaration (Art. 7(6)).
What does CBAM ask from a producer outside the EU?
The Regulation places the declaration and the certificates on the declarant, not on the producer. But the declarant determines embedded emissions in one of two ways: from actual emissions or by reference to default values (Art. 7(2)). Actual emissions are your installation's data.
- Actual emissions: calculated from your production data. On this route the figure is verified by an accredited verifier (Art. 8(1)). The producer prepares an emissions report and a summary of it, and the report is submitted in English (2025/2547 Art. 10(1), 10(4)).
- Default values: set at the average emission intensity of the exporting country, increased by a mark-up (2023/956 Annex IV, point 4.1). If you give no data, this is what your buyer uses.
The Regulation calls the producer the "operator": the person that operates an installation in a third country (Art. 3(31)). An operator may ask to be registered in the CBAM registry; registration is valid for five years (Art. 10(1), 10(3)). A registered operator may disclose its verified information to a declarant, who may use it (Art. 10(7), Art. 8(2)).
We cover the report itself in the CBAM report for producers.
Which sectors does CBAM cover?
Annex I has six headings. Scope is decided by the CN code of the product, not by the name of the sector (Annex I, point 1).
| Sector | Example CN codes | Greenhouse gas |
|---|---|---|
| Cement | 2523 10 00, 2523 29 00 | Carbon dioxide |
| Electricity | 2716 00 00 | Carbon dioxide |
| Fertilisers | 2808 00 00, 2814, 3102, 3105 | Carbon dioxide; for most codes also nitrous oxide |
| Iron and steel | Chapter 72, and the listed headings of Chapter 73 | Carbon dioxide |
| Aluminium | 7601, 7604, 7606, 7616 | Carbon dioxide and perfluorocarbons |
| Chemicals | 2804 10 00 (hydrogen) | Carbon dioxide |
Source: 2023/956 Annex I. Which code groups are in and which are out is set out in a table in CBAM product scope and CN codes.
Origin matters too. The Regulation does not apply to goods originating in Iceland, Liechtenstein, Norway or Switzerland (Art. 2(4), Annex III, point 1). For producers in Türkiye: Türkiye is not on that list.
What is the 50-tonne threshold and who does it apply to?
The threshold applies to the importer, not to the producer. An importer is exempt from the obligations of the Regulation where the net mass of the in-scope goods it imports in a calendar year does not cumulatively exceed 50 tonnes (Art. 2a(1), Annex VII, point 1).
- It is counted per importer and per calendar year, with all CN codes added together (Art. 2a(1)).
- Once the threshold is exceeded within the year, the obligations cover all emissions embedded in all goods imported in that year (Art. 2a(2)).
- It does not apply to imports of electricity or hydrogen (Art. 2a(4)).
- The Commission reassesses the threshold by 30 April each year (Art. 2a(3)).
Your sales to one buyer may be under 50 tonnes. If that buyer also imports in-scope goods from other suppliers, its total can still pass the threshold, and it will need data for your shipments too.
When did CBAM start, and what are the key dates?
| Date | What happens | Source |
|---|---|---|
| 1 October 2023 | The transitional period started. The importer's obligations were limited to reporting, quarter by quarter. | Art. 32, Art. 35(1) |
| 31 December 2025 | The transitional period ended. | Art. 32 |
| 1 January 2026 | The definitive period started: authorised declarant, yearly declaration, calculation, verification and surrender apply. | Art. 36(2)(b) |
| 1 January 2027 | At each quarter end the declarant holds certificates for at least 50 % of the emissions embedded in goods imported since the start of the year. | Art. 22(2), Art. 36(2)(c) |
| 1 February 2027 | Sale of CBAM certificates on the common central platform starts. | Art. 20(1), Art. 36(2)(d) |
| 30 September 2027 | First yearly declaration and surrender, for the year 2026. Then 30 September every year. | Art. 6(1), Art. 22(1) |
| 31 October each year | Last day to request the repurchase of excess certificates. | Art. 23(1) |
Is there a CBAM payment in 2026?
No certificates are sold in 2026: sales start on 1 February 2027 (Art. 20(1)). But goods imported in 2026 do need certificates for their emissions. The declaration and the surrender are due by 30 September 2027 (Art. 6(1), Art. 22(1)).
For 2026 emissions the certificate price is the average of the closing prices of EU ETS allowance auctions in the quarter in which the goods were imported (Art. 21(1a)). For later years it is calculated as a weekly average (Art. 21(1)).
Two items reduce the number of certificates: the adjustment that reflects free allocation inside the EU (Art. 31) and a carbon price effectively paid in the country of origin (Art. 9(1)). The declarant buys and surrenders the certificates. How that cost is shared with you is not in the Regulation; it is a matter for your contract. More on the certificate in CBAM certificate and its price.
Where to start?
- With your buyer, list the CN codes of the products you ship to the EU and compare them with Annex I.
- Ask your buyer whether it passes the 50-tonne threshold.
- Agree whether the declaration will use actual emissions or default values.
- For actual emissions, start collecting production and energy data. For goods imported in 2026 the reporting period is the year 2026 (2025/2547 Art. 7(1)).
- Leave time for verification: the figure has to be verified before the declaration of 30 September 2027 (2023/956 Art. 6(2)(b), Art. 8(1)).
The Registamp CBAM module calculates embedded emissions per product from your installation and invoice data and prepares the verifier file and the buyer summary. See the CBAM module page.
This article is general information, not legal advice. For your own case, refer to the text of the Regulation and, where needed, to a specialist.
Sources
- Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism (read from the consolidated text of 20 October 2025): eur-lex.europa.eu/eli/reg/2023/956/oj
- Regulation (EU) 2025/2083 amending Regulation 2023/956 (50-tonne threshold, date of the yearly declaration): eur-lex.europa.eu/eli/reg/2025/2083/oj
- Implementing Regulation (EU) 2025/2547 on the methods for calculating embedded emissions: eur-lex.europa.eu/eli/reg_impl/2025/2547/oj