EU Market ReadyCBAM 2026-2027 readiness guide
CBAM 2026-2027 guide for importers covering goods scope, 50-tonne exemption, reporting cadence, certificate costs, supplier emissions data, and examples.
CBAM 2026 2027 guide
Europe’s Carbon Border Adjustment Mechanism (CBAM) demands quarterly reporting for covered goods starting 2026, with certificates required from 2027. Treat this guide as operational direction—not legal advice. Use the CBAM Readiness Tool to generate your first exemption or cost scenario and keep updates logged in the Readiness Check for customs/audit alignment.
Feed HS/CN codes and supplier emissions data into the CBAM Readiness Tool while you read; data alignment saves weeks later.
Pair CBAM readiness with VAT/storage planning via the EU compliance checklist so customs and tax narratives match.
Scope overview
Covered goods & CN codes
| Product family | CN codes | Example goods | Notes |
|---|---|---|---|
| Iron & steel | 7206–7217 | Slabs, coils, bars | Include alloys and stainless variants |
| Aluminum | 7601–7609 | Ingots, plates, profiles | Declare alloy composition |
| Cement | 2523 | Clinker, grey cement | Watch moisture content |
| Fertilizers | 3102–3105 | Urea, ammonia, NPK mixes | Include additives |
| Electricity | 2716 | Imported electricity | Country of origin required |
| Hydrogen | 2804 | Hydrogen gas/liquid | Emissions data scarce; start early |
50-tonne small importer rule
| Metric | Requirement | Evidence |
|---|---|---|
| Annual volume | ≤ 50 tonnes per covered category | Invoices, customs declarations |
| Reporting | Still file simplified report | Keep supplier attestations |
| Certificates | No purchase obligation until threshold exceeded | Document methodology in SOP |
| Monitoring | Rolling 12-month review | Use BI dashboards tied to Readiness Check data |
Reporting cadence
Transitional phase (2023–2025)
Quarterly reports
Contents
Notes
- Quantity of goods (tonnes), embedded emissions, carbon price paid abroad.
- Submit within one month after quarter-end.
Data collection
Contents
Notes
- Request supplier-specific emissions or use default values until 2025.
- Store calculations in tamper-proof system (SaaS or internal DB).
Definitive phase (2026 onward)
Certificates purchase
Steps
Notes
- Buy CBAM certificates equal to embedded emissions minus foreign carbon price credit.
- Price pegged to weekly EU ETS average.
Reconciliation
Steps
Notes
- Annual reconciliation by May 31 each year.
- Surrender surplus certificates for refund or carryover.
Cost planning
Budget ranges
| Cost bucket | Estimated range | Drivers | Linked doc |
|---|---|---|---|
| Supplier data validation | EUR 5k–EUR 30k | Consultants, audits | EU VAT explained for shared records |
| IT integration | EUR 10k–EUR 80k | Data lakes, dashboards | EU compliance checklist |
| Certificates | Variable | ETS price, emissions factor | EU compliance FAQ |
| Legal & filings | EUR 3k–EUR 15k | Declarant setup | French & German packaging for combined disclosures |
Timeline milestones
| Milestone | Target date | Owner | Notes |
|---|---|---|---|
| Supplier outreach complete | Q1 2025 | Supply Chain | Include emission methodology contract clause |
| Reporting templates live | Q2 2025 | Data/IT | Align with GDPR basics for data minimization |
| Declarant registration | Q4 2025 | Legal | Choose member state of establishment |
| Certificate procurement playbook | Q1 2026 | Finance | Model ETS price ranges |
Industry examples
Steel
Hot-rolled coils
Risks
Actions
- Emissions vary by mill; request site-specific data quarterly.
- If re-exporting within EU, maintain chain-of-custody proof.
Fabricated steel parts
Risks
Actions
- Even if final product assembled outside EU, embedded steel still counts when imported.
- Map BOM to CN codes precisely.
Aluminum
Billets
Risks
Actions
- Alloy composition affects emission factors—capture certificates.
- Watch for double-counting when billet becomes extrusions internally.
Extrusions
Risks
Actions
- Keep scrap credit calculations transparent.
- Coordinate with VAT documentation if goods route via multiple EU states.
Fertilizers
Urea imports
Risks
Actions
- Track natural gas feedstock origin; affects default emissions.
- Compare tariffs vs CBAM cost to optimize sourcing.
Blended products
Risks
Actions
- Determine whether additives push CN classification outside CBAM scope.
- Document reasoning for audits.
Governance & monitoring
Weekly rituals
Data quality stand-up
Owners
Checklist
- Review missing emission factors per supplier.
- Update dashboards with actual tonnage.
Regulatory watch
Owners
Checklist
- Track EU delegated acts, publish notes to Blog.
- Sync packaging/DSA teams when sustainability messaging changes.
Monthly rituals
Reconciliation dry run
Owners
Checklist
- Simulate certificate purchase vs ETS price.
- Validate that privacy controls from GDPR basics cover CBAM datasets.
Stakeholder comms
Owners
Checklist
- Share highlights with finance, sustainability, legal.
- Refresh risk register linking to EU market quick start.
Ready to check your obligations? Run the Readiness Check → Start CBAM planning
Next steps
- Run the Readiness Check for your scenario → Start now
- Use the CBAM Readiness Tool → Open tool
- Share this guide with finance / ops teammates.
FAQ
Do I qualify for the CBAM 50-tonne exemption?
You may use the small-importer simplification if covered goods stay at or below 50 tonnes per CN category in a rolling 12 months. You still file quarterly reports with quantities and emissions. Track tonnes by CN code, keep customs declarations and supplier attestations, and set alerts as you approach the limit to avoid missing the switch to full certificate purchases.
What supplier data do I need for CBAM?
Collect CN codes, quantities, embedded emissions, and any carbon price paid abroad. Ask suppliers for site-specific emission factors; use EU defaults only as a fallback. Store attestations, calculations, and contracts in tamper-evident storage so quarterly reports and reconciliations can be defended during audits.
When should I appoint a CBAM declarant?
Ahead of 2026–2027 requirements, appoint an authorized CBAM declarant once you confirm covered goods and expect to exceed the small-importer threshold. Register early, align data exports from your warehouse/BI tools, and prepare to buy certificates when the definitive phase starts. Keep a calendar for reporting deadlines to avoid penalties.
How do I budget for CBAM certificates?
Model emissions by supplier and CN code, apply the projected EU ETS price minus any foreign carbon price credit, and simulate quarterly purchases. Run sensitivity scenarios to handle price volatility, and build a reconciliation routine by May 31 each year. Keep finance, sustainability, and legal aligned on assumptions and hedging decisions.