EU Compliance 2026

CBAM Compliance Guide for Manufacturing Importers

The EU Carbon Border Adjustment Mechanism is live. If you import iron, steel, or aluminium goods from outside the EU, you now need a CBAM declarant registration and quarterly certificate purchases. Here's what that means in practice.

Source from CBAM-ready suppliers →

TL;DR

CBAM definitively entered force on 1 January 2026. All imports of in-scope goods require authorised declarant status.
In-scope for manufacturers: iron & steel (HS 72–73), aluminium (HS 76), and specific downstream goods incorporating these materials.
Certificate price ≈ weekly average EU ETS price per tonne CO₂ of embedded emissions.
Suppliers that can prove lower embedded carbon reduce your certificate obligation — ask for verified emissions disclosures.

1. What CBAM means for you

From 1 January 2026: importing any CBAM-covered goods without being a registered declarant is a customs offence. Penalties can reach 3× the avoided CBAM cost.

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 quarterly compliance workflow

Apply with your national competent authority (e.g., Hauptzollamt in Germany, HMRC in UK-equivalent). Process takes 4–8 weeks.

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 × (1 − carbon price adjustment for any carbon already paid in the country of origin).

Purchase CBAM certificates

Buy via the CBAM Registry. Price = weekly average EU ETS carbon price. Certificates not used can be sold back (max 1/3 of purchased).

File quarterly CBAM declaration

Submit via EU CBAM Registry: goods, quantities, embedded emissions, certificates surrendered. Deadline: 31 May of the following year for annual declaration.

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 — a Chinese aluminium smelter running on hydropower emits ~4–6 kg CO₂/kg Al vs. the global average of ~11.5 kg CO₂/kg Al. That's a 55% lower CBAM obligation.
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 suppliers are asked to provide embedded emissions declarations. This data appears in the order summary to help you calculate your CBAM obligation before committing.

Frequently asked questions

When does CBAM enter the definitive period?

1 January 2026 — quarterly reporting and certificate purchase obligation begin. The transitional phase (reporting only, no purchase) ran from October 2023 to December 2025.

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?

CBAM certificate prices are linked to the weekly average EU ETS (Emission Trading System) carbon price. If EU ETS is at €70/tonne CO₂, a CBAM certificate for 1 tonne of embedded emissions costs €70.

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

Yes. From 1 January 2026, only authorised CBAM declarants (registered with the national competent authority in your EU country) may import CBAM goods. Registration takes 4–8 weeks — apply now if not already registered.

Source from CBAM-disclosed suppliers on FabriMatch →