In short
CBAM is the EU carbon price at its border. Since 1 January 2026, importers of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen must surrender certificates against the emissions embedded in what they bring in. Verified supplier data almost always costs less than the EU’s default values.
What it is
The EU Carbon Border Adjustment Mechanism prices the carbon embedded in imports of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. In its definitive regime, it carries a real financial cost.
Why it matters
Verified embedded-emissions data almost always beats punitive default values — protecting margin. Scope confirmation is the first step, because the rules changed just before the definitive regime began.
The financial regime is now live: CBAM’s definitive phase began on 1 January 2026 (European Commission, 2026). The Omnibus 50-tonne de minimis exempts roughly 90% of importers while still covering about 99% of embedded emissions (European Commission, 2026). The Q1 2026 reference price was €75.36 per tonne of CO₂, with a €100-per-tonne penalty for non-surrender, and the first declaration for 2026 imports is due 30 September 2027 (Gerlach Customs; Coolset, 2026).
What & how we do it
The work, in the order we do it.
- Confirm exactly where you sit in scope — the rules changed just before the definitive regime began
- Calculate product-level embedded emissions
- Produce verified data to replace defaults
- Model the margin impact
- Support your declarants through submission
Standards & frameworks
- EU CBAM Regulation
- Underpinned by rigorous PCF and GHG data
The rules, as they stand
What the regulation actually says.
| Position as at September 2026 | |
|---|---|
| Status | Definitive regime — financial obligations applyEuropean Commission |
| Sectors covered | Cement, iron & steel, aluminium, fertilisers, electricity and hydrogen, plus selected precursor goodsEuropean Commission |
| De minimis threshold | 50 tonnes a year (Omnibus, Regulation (EU) 2025/2083) — exempts roughly 90% of importers while still covering about 99% of embedded emissionsEuropean Commission; Spectreco, 2026 |
| Reference price | €75.36 per tonne CO₂ in Q1 2026, tracking the EU ETSGerlach Customs; Coolset, 2026 |
| Adjustment factor | 2.5% in 2026, phasing to full cost by 2034Gerlach Customs; Spectreco, 2026 |
| Penalty | €100 per tonne for non-surrenderGerlach Customs; Coolset, 2026 |
Key dates
- Oct 2023 – Dec 2025Transitional phase — reporting only, no financial cost.
- 1 January 2026Definitive regime begins. Financial obligations apply.
- February 2027CBAM certificate sales open.
- 30 September 2027First declaration and surrender, covering 2026 imports.
- Through 2034Free allocation phases out and the adjustment factor reaches full cost.
Common questions
Six: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen — plus selected precursor goods. Confirming exactly where your product codes sit is the first piece of work, because the boundary moved shortly before the definitive regime began.
It might. The Omnibus de minimis under Regulation (EU) 2025/2083 exempts importers below 50 tonnes a year — roughly 90% of them — while still covering about 99% of embedded emissions. That is precisely why scope confirmation comes before anything else.
The Q1 2026 reference price was €75.36 per tonne of CO₂, tracking the EU ETS. A 2.5% adjustment factor applies in 2026 and phases up to full cost by 2034, so today’s exposure is a fraction of the exposure being built in.
Where reliable supplier data is missing, the EU applies default values — and they are deliberately conservative, which usually means higher. Verified product-level embedded emissions typically lower the bill, which is why this is a margin question rather than a paperwork one.
A penalty of €100 per tonne, on top of the certificate cost that was avoided.
30 September 2027, covering 2026 imports. Certificate sales open in February 2027, so the data work has to be finished well before either date.
The declaration sits with the EU-side declarant. Almost all of the work sits upstream with you: the product-level embedded-emissions data they cannot file without. We calculate it and support your declarants with it.
Directly. CBAM charges on embedded emissions, and a rigorous product carbon footprint is what produces verified figures to put in place of defaults. The two pieces of work are the same evidence base.
Related reading
What we have written on this.
CBAM strategy for iron & steel: what exporters must decide in 2026
CBAM is now a carbon price at the EU border for steel — the widest scope, the highest emissions. Verified data vs default values, and how to turn it into an edge.
10 min read RegulationCBAM in 2026: the definitive period, the Omnibus simplification, and what exporters must do now
From 1 January 2026 the EU Carbon Border Adjustment Mechanism stops being a reporting exercise and becomes a cost. What changed, who is now exempt, and the moves that protect your margin.
9 min readProtect your EU margin.
Send us your CN codes and import volumes and we will model what defaults are costing you.
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