8 min readUpdated 2026-10-11

EU 2023/956

CBAM — Carbon Border Adjustment Mechanism

Carbon pricing at the EU border. Definitive phase from January 2026 with mandatory certificate purchases for embedded emissions in imported goods.

Comply by

See key dates

Max penalty

Not specified

Sectors

All sectors

DPP required

Pending

In force since: 20 May 2023Last verified: 11 Oct 2026

Overview

The Carbon Border Adjustment Mechanism (CBAM) — Regulation (EU) 2023/956 — puts a carbon price on imports of certain goods to prevent carbon leakage and ensure a level playing field for EU producers under the Emissions Trading System.

Legal basis

Proposed: 14 July 2021
Adopted: 10 May 2023
Transitional phase: 1 October 2023 - 31 December 2025
Definitive phase: 1 January 2026

Covered products

Cement
Iron and steel
Aluminium
Fertilisers
Electricity
Hydrogen

Transitional phase (Oct 2023 - Dec 2025)

Quarterly reports on imported quantity and embedded emissions
No certificate purchase required
Actual or default emissions values permitted

Definitive phase (from January 2026)

Annual CBAM declaration required; the first, covering 2026 imports, is due 30 September 2027
Authorised CBAM Declarant status required
CBAM certificates purchased and surrendered annually
First certificate surrender: 30 September 2027 (for 2026 emissions)
Verified emissions data from producers required
Third-party verification mandatory

2025 simplification

Regulation (EU) 2025/2083 of 8 October 2025, in force since 20 October 2025, simplified CBAM. It introduced a 50-tonne annual exemption: importers with fewer than 50 tonnes/year total of all CBAM goods are exempt.

The threshold stays at 50 tonnes. In its assessment published on 30 September 2026, the Commission found that, for 1 April 2025 to 31 March 2026, the threshold would exempt 0.87% of embedded emissions, below the 1% limit set in Article 2a(3) (European Commission, 30 September 2026).

CBAM certificate price

The certificate price reflects the average EU ETS allowance auction clearing price, calculated under Commission Implementing Regulation (EU) 2025/2548.

Period	Price per certificate	Published
Q1 2026	€75.36	7 April 2026
Q2 2026	€75.28	6 July 2026
Q3 2026	€82.32	5 October 2026
Q4 2026	Due 4 January 2027	—

For 2026 the Commission publishes one price per calendar quarter, and each quarterly price applies to certificates for goods imported in that quarter. From 2027 prices are published weekly. From February 2027, all CBAM certificates are purchased on the common central platform (Art 20) (European Commission, price of CBAM certificates).

Verifiers

Accredited verifiers have been able to access the CBAM Registry since 1 September 2026 and issue verification reports in the Registry from January 2027. On 28 September 2026 the Commission published an overview of resources for CBAM verifiers and new training videos for accredited verifiers.

Proposed extension to downstream goods

Status: proposed, not law. Procedure 2025/0419(COD), based on Commission proposal COM(2025) 989 of December 2025, would extend CBAM to certain downstream products and add anti-circumvention measures.

Council general approach: 12 June 2026
European Parliament: on 15 September 2026 Parliament adopted amendments to the proposal by 464 votes to 50, with 159 abstentions, and referred the file back to committee for negotiations with the Council. It has not adopted a first-reading position (Legislative Observatory, 2025/0419(COD))
Aluminium threshold: Parliament's amendments include a separate 5-tonne threshold for aluminium products. This is a Parliament amendment only and has not been agreed with the Council (European Parliament, adopted text TA-10-2026-0276)
Next step: trilogue negotiations between Parliament and Council

The institutions' draft lists of downstream products differ considerably, so the final scope is not yet known. Norruva will list covered products only once a text is adopted.

Iceland and Norway

Iceland and Norway are joining CBAM through the EEA Agreement. EEA Joint Committee Decision 283/2026, adopted on 25 September 2026, brings the CBAM Regulation into the Agreement. It is not yet in force, and Liechtenstein is excluded. Under the draft decision on which the EU position was based, the definitive period would apply to the two countries from 1 January 2027 (expected, once the decision is in force) (Council Decision (EU) 2026/2240; EEA-Lex, Regulation (EU) 2023/956).

Steel imports: country of melt and pour

A separate customs rule applies to steel importers alongside CBAM. Since 1 October 2026, importers of the steel products covered by Regulation (EU) 2026/1384 must prove at import the country of "melt and pour", where the steel was first produced in liquid form and cast. The evidence is a mill test certificate that names the country of melt and pour and the heat number. Until 30 September 2027, if no certificate is available, customs may accept other documents, such as invoices or supplier declarations, that give the same information. Without this evidence, customs rejects the import (Regulation (EU) 2026/1384, Art 4(1); Implementing Regulation (EU) 2026/1963).

Penalties

CBAM penalties are among the most mechanically precise of any EU sustainability regulation:

€100 per excess tonne of CO2 equivalent not covered by surrendered certificates (Art. 26) — no maximum cap on total penalty exposure
Transitional phase (through December 2025): national fines of €10–€50 per tonne of unreported or incorrectly reported emissions; higher rates applied for repeated non-compliance
Failure to register as an Authorised CBAM Declarant: member states set proportionate penalties; importing without declarant status may result in customs refusal
Criminal penalties possible under national law in several member states for deliberate evasion

The absence of a cap means large importers face unconstrained financial exposure for material underreporting.

Who is affected

All importers of CBAM-covered goods above the 50-tonne annual threshold:

Importers of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen into the EU customs territory
Authorised CBAM Declarant status required — companies must register with the competent authority in their member state of establishment; existing importers had until 31 March 2026
Customs agents and indirect representatives may submit declarations on behalf of importers but the economic operator retains liability
Importers below 50 tonnes/year total across all CBAM goods are exempt under the Simplification Regulation (EU) 2025/2083

The first annual declaration and certificate surrender fall on 30 September 2027 (covering 2026 imports).

Key articles

Article	Subject
Art. 4	Authorised CBAM Declarant — registration requirement and conditions
Art. 6	CBAM declaration — annual submission covering the prior calendar year (first due 30 September 2027)
Art. 7	Calculation of embedded emissions
Art. 26	Penalties — €100 per excess tonne of CO2 equivalent; no cap
Art. 35	Transitional period reporting obligations

Relevance to DPP

CBAM is adjacent to DPP in the carbon data ecosystem:

Both require product-level carbon footprint data
Companies calculating carbon footprints for batteries (Battery Regulation) may reuse methodology for CBAM
Harmonisation of carbon footprint methodologies across regulations is ongoing

Key dates

Date	Milestone
1 October 2023	Transitional phase begins (reporting only)
1 January 2026	Definitive phase — certificate obligations apply
31 March 2026	Authorised CBAM Declarant application deadline
7 April 2026	Q1 2026 certificate price published (€75.36)
6 July 2026	Q2 2026 certificate price published (€75.28)
1 September 2026	Accredited verifiers can access the CBAM Registry
15 September 2026	Parliament adopts amendments to the downstream-extension proposal and refers it back for trilogues (proposal, not law)
25 September 2026	EEA Joint Committee Decision 283/2026 adopted: Iceland and Norway to join CBAM (not yet in force)
28 September 2026	Commission publishes resources and training videos for verifiers
30 September 2026	Commission assessment keeps the 50-tonne threshold
5 October 2026	Q3 2026 certificate price published (€82.32)
4 January 2027	Q4 2026 certificate price due
February 2027	Certificate sales open on the common central platform; weekly pricing
30 September 2027	First annual declaration and certificate surrender (for 2026 imports)

Source

CBAMCarbonEmissionsEU 2023/956Border