The Carbon Border Adjustment Mechanism (CBAM) obliges EU companies to purchase certificates for emissions-intensive imports from 2027. Starting 2028, 180 additional products will be affected. The UK is following suit. An overview.
Sustainability is becoming a necessity: Reducing CO₂ emissions is an important EU target. To achieve this, the carbon border adjustment mechanism CBAM is intended to supplement the European emissions trading system established in 2005, which is considered a central element of CO₂ reduction. With this, the EU encourages a more careful approach to CO₂ emissions worldwide and limits possible economic disadvantages caused by "CO₂ leakage", i.e. the migration of industries to countries with less stringent regulations on CO₂ emissions.
In short: Anyone importing emissions-intensive goods into the EU will in future have to purchase CBAM certificates to compensate for the difference between the cost of CO₂ emissions in the country of production and the price of CO₂ certificates in the EU. A quarterly price will apply for 2026 and weekly prices will be charged from 2027. The first price on April 7, 2026, was 75.36 euros.
CBAM was introduced in 2023 and has been revised several times since then. Applicants affected by it must now submit annual CBAM declarations by September 30 of the following year. The sale of CBAM certificates starts on February 1, 2027 and covers emissions from 2026.
The legal foundations were laid with Regulation (EU) 2023/956. As part of the Omnibus initiative, the application of the regulation was simplified. The EU provides an overview of regulations and assistance on its Carbon Border Adjustment Mechanism website.
This year, the EU publishes the prices of CBMA certificates on a quarterly basis. The next one has been announced for July 7, 2026. Weekly prices are to follow from 2027.
All companies that act as importers in the EU and, as such, import goods listed in Annex I of Regulation (EU) 2023/956 from third countries are affected. This concerns goods from the following sectors:
In mid-December 2025, the EU Commission announced that around 180 additional downstream products would be covered by the CBAM regulation from 2028. On June 12, 2026, the Council of the EU further expanded the proposal. The draft of the new regulation now also includes products with a high steel or aluminum content, such as household appliances, hardware, vehicle components, and construction machinery. This means, for example, that refrigerators and washing machines would also fall under the CBAM. The Parliament’s position is now awaited. An agreement and the publication of the regulation are expected by the end of the year.
Originally, all goods covered by EU emissions trading were to be included by 2030.
Note: The decisive factor is the commodity code in the first four to eight digits (HS code and sometimes also CN code). If the commodity code is listed in Annex I, the goods are affected.
Product Classification is a reliable, intuitive tool for finding just the right import and export commodity code and export control number – in a process that can be manual, automated, or customized to your precise needs.
The most important change from the Omnibus package of February 2025 regarding CBAM concerns the de minimis threshold. Previously, imports from 150 euros per shipment were subject to the CBAM regulation.
Regulation (EU) 2025/2083 introduced a quantity limit of 50 tons per year. Importers who do not exceed this threshold within a year are therefore not subject to any additional reporting obligations. This measure exempted over 90 percent of the companies previously affected from the CBAM obligation.
CBAM declarations are also not required for goods originating in the countries and territories listed in Annex III Section A – currently Switzerland, Liechtenstein, Norway, and Iceland. This also applies to products manufactured in a third country under the outward processing procedure.
Note: The de minimis threshold is defined in Article 2a and further exceptions are defined in Article 2 and Article 34 of Regulation (EU) 2023/956.
A CBAM declaration must be submitted by the declarant or, if the declarant is not established in the EU, by the declarant's indirect representative.
Declarations are made via the EU CBAM Portal (TAXUD). Importing companies within the EU always receive the access data via their national authority. Access management is carried out via the national customs portal – instructions from the respective EU Member State must be observed.
In the CBAM transitional phase from 2023 to 2025, importers affected by CBAM had to report the direct and indirect greenhouse gas emissions embedded in their imports without purchasing certificates.
On January 1, 2026, the "definite period" (standard phase) began, in which EU importers or their indirect customs representatives who import more than the single mass threshold of 50 tons of CBAM goods into the EU must have the status of approved CBAM declarant. CBAM certificates must be purchased from the national authorities in the respective country of registration from 2027. The price of the certificates will be calculated on the basis of the auction price of EU ETS certificates.
If importers can prove that a CO2 price has already been paid during the production of the imported goods, the corresponding amount can be deducted.
Plant operators from third countries can also upload their details to the CBAM register. However, if companies do not receive emissions data from suppliers for imported CBAM goods, they can also access default values in the standard phase. These were published in the Official Journal of the EU Commission on December 31, 2025 with Implementing Regulation (EU) 2025/2621 . The values are generally higher than the actual emissions and will be gradually provided with additional mark-ups until 2028. Fertilizers will only be subject to lower surcharges – further reductions are being discussed for the agricultural sector.
A technical study published in May 2026 outlines the potential future development of the Carbon Border Adjustment Mechanism (CBAM) with regard to indirect emissions embedded in goods imported from third countries. The Technical Study on Indirect Emissions in the CBAMis available exclusively in English and comprises 107 pages.
Tip: If you use AEB for your import processing, you can extract data from the system and analyze it in Excel. For example, AEB provides a CBAM data extract free of charge in the Import Filing: ATLAS standard.
CBAMBOO is building a decarbonization network around the world.
It is not only in the EU that border adjustment is being promoted: Norway wants to participate in EU CBAM as part of voluntary cooperation, according to the Norwegian government in its press release dated October 7, 2024. The Norwegian Environmental Protection Agency provides information on the planned introduction from January 1, 2027, on their website. The first declarations are planned from 2028.
The introduction of CBAM in the UK from January 1, 2027, is regulated by law in the Finance Act 2026. Importers of these listed goods are affected. In contrast to the EU, electricity is not affected. The de minimis threshold is 500,000 pounds. Global, product-related standard values are to be provided for the calculation, rather than country-specific ones. The costs depend on the UK ETS, which is to be linked to the EU ETS in the long term – however, a legally effective agreement has yet to be reached. The costs will be collected as a tax. Current UK government guidance is available in the Policy Summary and HMRC plans to publish further details before 2027 to support businesses in preparing for the introduction of the tax and meet the new requirements.
