EU Compliance 2026

CBAM Compliance Guide for Manufacturing Importers

By Norbert Laszanowski · Updated 12 October 2026 · First published 17 May 2026

CBAM has applied in full since 1 January 2026. If you import more than 50 tonnes a year of iron, steel or aluminium goods from outside the EU, you need to be an authorised CBAM declarant and buy certificates for their embedded emissions. Here's what that means in practice.

Source from CBAM-ready suppliers →

TL;DR

CBAM has applied in full since 1 January 2026. Importers of 50 tonnes or less of CBAM goods a year are exempt; above that, you need authorised declarant status and CBAM covers all of that year's imports.
In-scope for manufacturers: iron & steel (HS 72–73), aluminium (HS 76), and specific downstream goods incorporating these materials.
One certificate per tonne of embedded CO₂, priced from EU ETS auctions — quarterly average for 2026 imports, weekly from 2027. For 2026 imports, certificates go on sale in February 2027 and the declaration is due by 30 September 2027.
Suppliers that can prove lower embedded carbon reduce your certificate obligation — ask for verified emissions disclosures.

1. What CBAM means for you

Above the 50-tonne threshold: importing CBAM goods without authorised declarant status, or failing to surrender enough certificates, is penalised under Article 26 of Regulation (EU) 2023/956.

CBAM is the EU's mechanism to put a carbon price on imports equivalent to what EU manufacturers pay under the Emissions Trading System (EU ETS). Without it, EU producers — who pay for their carbon — would be undercut by importers from countries with no carbon price.

For EU buyers sourcing metal parts from Asia, CBAM adds a compliance layer and, in some cases, a cost adder. Understanding it is not optional from 2026.

2. In-scope commodity groups (Annex I)

Sector	Key HS codes	Common manufactured goods affected
Iron & steel	HS 72, 73	Steel sheet metal parts, CNC steel components, welded assemblies, structural steel
Aluminium	HS 76	Aluminium CNC parts, extrusions, castings, sheet metal from aluminium
Cement	HS 2523	Portland cement, clinker
Fertilisers	HS 31	Nitric acid, ammonia-based fertilisers
Electricity	HS 2716	Electricity imports (cross-border grid)
Hydrogen	HS 2804.10	Green/grey hydrogen imports

Important for CNC buyers: Aluminium CNC parts (HS 7616 — articles of aluminium) are in scope. Steel machined components (HS 7326) are in scope. If you buy these from Asian suppliers, you need CBAM certificates.

3. The annual compliance workflow

Check the threshold, then register

Add up your CBAM goods for the calendar year. If you will exceed 50 tonnes, apply for authorised CBAM declarant status with your national competent authority before you do.

Collect embedded emissions data

Request verified embedded emissions per tonne from each supplier. Accepted formats: ISO 14064, Scope 1+2 per EU CBAM Regulation Annex III.

Calculate certificate obligation

Certificates needed = tonnes of embedded CO₂e imported, minus a deduction for any carbon price already paid in the country of origin and an adjustment for EU free allocation.

Purchase CBAM certificates

Buy through the central CBAM platform — from February 2027 for 2026 imports. Price follows EU ETS auctions: quarterly average for 2026, weekly from 2027. During the year, hold enough certificates at each quarter-end to cover part of your imports.

File the annual CBAM declaration

Submit via the CBAM Registry: goods, quantities, embedded emissions and certificates surrendered. Deadline: 30 September of the following year — 30 September 2027 for 2026 imports.

4. How to reduce your CBAM cost

Your CBAM certificate obligation is proportional to your suppliers' embedded carbon intensity. The strategies to reduce it:

Source from low-carbon suppliers — most of primary aluminium's footprint is the electricity used to smelt it, so metal from hydropower-powered smelters carries far less embedded CO₂ than metal from coal-powered ones, and a correspondingly smaller certificate bill.
Require verified emissions disclosure — a supplier who can provide third-party verified embedded emissions per the Regulation reduces your obligation vs. using default values.
Consider EU sourcing for aluminium-heavy parts — EU aluminium producers already pay EU ETS. No CBAM cost when buying within the EU.
Re-evaluate part material — where feasible, plastic or composite alternatives have zero CBAM obligation.

FabriMatch asks suppliers for embedded emissions declarations. Where a supplier has provided one, its match card shows a CBAM badge and the embedded emissions in kg CO₂e per kg, so you can estimate the certificate cost before you order.

Frequently asked questions

When does CBAM enter the definitive period?

1 January 2026. The transitional phase (quarterly reporting only, no payment) ran from October 2023 to December 2025. For goods imported in 2026, certificates go on sale from February 2027 and the first annual CBAM declaration is due by 30 September 2027.

Which commodity groups are in scope for CBAM?

Cement, iron & steel, aluminium, fertilisers, electricity, and hydrogen. Downstream manufactured goods that incorporate these materials are also covered if they fall within specific HS codes listed in Annex I of Regulation (EU) 2023/956.

How is the CBAM certificate price calculated?

From EU ETS allowance auction prices. For goods imported in 2026 the price is the quarterly average (Q1 2026 was €75.36 per tonne of CO₂); from 2027 it is the weekly average. One certificate covers one tonne of embedded emissions.

Do I need a CBAM declarant status to import steel from China?

Only above the threshold. If your imports of CBAM goods (iron and steel, aluminium, cement, fertilisers) stay at or below 50 tonnes in a calendar year, you are exempt. Once you exceed 50 tonnes, CBAM applies to everything you imported that year, so you must be an authorised CBAM declarant — apply to your national competent authority before you cross it.

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