The Carbon Border Adjustment Mechanism (CBAM) obliges companies to purchase CO₂ certificates for emissions-intensive imports from 2027. The Omnibus package has made things easier. An outlook.
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.
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.
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. These are mainly industrial products with a content of high steel or aluminum. As soon as extensions have been decided on, they will be included in the annexes.
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. If companies or indirect representatives have submitted an application to become an approved CBAM declarant, the regulation allows imports to continue until March 31, 2026. Originally, the date was set for January 1, 2026.
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. This will be used as a quarterly average in 2026 and as a weekly average from 2027.
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.
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.
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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 UK has also announced UK CBAM from 2027 – more information is available in the Factsheet: UK Carbon Border Adjustment Mechanism.
