CBAM 2026: Who is affected, 50-tonne threshold, costs & obligations

The CBAM Regulation 2023/956 (CBAM-VO) will enter into force on January 1, 2026.

From this point on, the product groups covered by the regulation – cement, iron and steel, aluminum, fertilizers, electricity, and hydrogen – may only be released for free circulation if the declarant is registered as an authorized CBAM declarant.

For the product groups cement, iron and steel, aluminum, and fertilizers, a quantity threshold of 50 tons per year applies, below which no authorization as a CBAM declarant is required. Electricity and hydrogen, on the other hand, are subject to the CBAM regardless of the quantity imported and thus without the application of a threshold value.

The introduction of the 50-ton limit is a new feature that was added as part of the CBAM omnibus package and is intended in particular to ease the burden on small importers. It states: “This threshold applies to the total weight of all goods of all CN codes, aggregated per importer and per calendar year.” (European Union, 2025). This means that the CBAM obligation applies if the total weight of all CBAM-relevant goods in the year under consideration exceeds 50 tons.

When are you subject to CBAM

You are affected if all three points apply:

You are affected if all three points apply:

1. Imported goods from a third country into the EU (origin determines)
2. The goods fall under a CBAM commodity code:
   • Iron & steel (tubes, profiles, sheets)
   • Aluminum (cast and extruded profiles)
   • Certain intermediate products (depending on CN code)
   • Cement
   • Fertilizers
3. The goods are released for free circulation (customs status applies). This means that imported goods are freely available on the EU internal market after customs declaration and payment of duties – only then does the CBAM obligation arise. In this case, the following is required:
   • Authorization as a CBAM declarant
   • Y128 in the customs declaration (see table below)
   • Emission data from the supplier
   • CBAM certificates (subject to duty from 2027)

Who is subject to CBAM

1️⃣ Does the goods come from a third country (non-EU)?

❌ No → No CBAM

✅ Yes → continue to 2️⃣

2️⃣ Are the goods released for free circulation in the EU for customs purposes?

(e.g., sale or use in the EU internal market)

❌ No (e.g., transit, customs warehouse, processing, re-export)

→ No CBAM yet

✅ Yes → continue to 3️⃣

3️⃣ Do the goods fall under a CBAM commodity code (Annex I CBAM Regulation)?

(e.g., iron & steel, aluminum, cement, fertilizers, electricity, hydrogen)

❌ No → No CBAM

✅ Yes → continue to 4️⃣

4️⃣ Is it electricity or hydrogen?

✅ Yes → Always subject to CBAM, as the 50-ton threshold does not apply

→  Authorized CBAM declarant + Y code required

❌ No → continue to 5️⃣

5️⃣ Does the imported annual quantity exceed 50 tons?

(applies to iron & steel, aluminum, cement, fertilizers)

❌ No (≤ 50 t/year)

→ CBAM goods, but no registration required

→ ❌ No Y code required

✅ Yes (> 50 t/year)

→ CBAM-liable

→ ✔ Authorized CBAM declarant + Y code required

From January 1, 2026, certain TARIC codes will be required in customs declarations for CBAM goods. Here is a list of the codes published to date:

What will change as of January 1, 2026

From this date onwards, the CBAM will be fully applicable: CBAM-relevant goods may only be imported by authorized CBAM declarants.

Customs will not release the goods for free circulation if:

• no authorized CBAM declaration is available or
• no valid CBAM certificate (Y code) is specified in the customs declaration. The Y code verifies the status of the authorized CBAM declarant. It is assigned on a company-specific basis and must be specified in every customs declaration for CBAM goods.

In addition to the customs declaration, there is a financial obligation: the purchase and surrender of CBAM certificates corresponding to the embedded emissions. The exact range of goods covered by the CBAM Regulation is set out in Annex I of the Regulation and is determined on the basis of the CN code.

Overview of the leaked benchmarks

For “simple goods” (excluding intermediate goods), there are now benchmarks at the production level (e.g., primary aluminum, ferrous alloys, and fertilizers). These are reference values for embedded emissions per product unit (e.g., tCO₂e per ton or kgCO₂e per kg of product), which are used as comparative or default/benchmark values in the CBAM mechanism. This means that in future, provided verified actual data is available, CBAM can be priced on the basis of the actual emission-specific intensity of production instead of being based on flat-rate default values.

👉 When importing aluminum/metals or steel: Clarify whether your imported items are considered simple or complex. While a uniform product-related emissions benchmark is applied to simple goods, steel products require consideration of intermediate products and the underlying process route. Emissions are therefore not assessed on the basis of a single flat-rate emissions value per ton, but on the basis of a differentiated composition of embedded emissions. If verified primary data is available, it can be used instead of flat-rate benchmark or default values.In short: For steel, an emissions-based bill of materials replaces the flat-rate benchmark – primary data beats default values.

For all goods, there are CN code-level “all-in” default values (flat-rate emission value per product unit), some of which are also process-level. Default values are available for 2026–28 and 2028–30.⚠️ Note: Default emission intensities are not (yet) fully available from the EU. Defaults are a “fallback” – but in practice they are often more expensive than primary data, i.e., direct emission data per product unit (product carbon footprints) from the supplier. Primary data must be verified by official sources. This requires ensuring adequate assurance of data accuracy by complying with the CBAM methodology.

👉 You must establish processes to avoid defaults (obtain supplier data).

For complex goods (with upstream products), there are “building blocks” for creating installation-specific benchmarks. The benchmark then depends on upstream products and emissions at the site.

👉 For many industrial inputs (especially metal/steel value creation), this boils down to site/plant-related primary data.

How much CBAM will cost

Simple goods (no precursors)

• SEFA = SFA
  • SEFA = Specific Embedded Free AllocationSpecifies how many embedded emissions per product unit are considered “free allocation.” This determines the portion of emissions that is subject to a charge.
  • SFA = Specific Free Allocation (prozessspezifische freie Zuteilung / Annex Column A)Specifies how many tCO₂e per product unit are allocated free of charge to an efficient plant.

👉 Benchmark logic relatively straight forward.

Complex goods (precursors)

• SEFA = Σ (mᵢ · SEFAᵢ) + SFA
  • Precursors are weighted (mᵢ = mass index-adjusted)
  • plus ein process-/location-related share (SFA)
    ‍
  👉 Pre-chain data (preliminary products) and site/process data required; therefore also a supply chain issue

Sample calculation with aluminium

Emission factor (e.g. 2.00 tCO₂e/t): either supplier-specific PCF (primary data) or, if this is not available, a default value

- (CBAM benchmark (z. B. 1.464 tCO₂e/t) x phase-in rate (z. B. 0.975))- carbon price paid overseas (in this example 0€)

x EUA price in 2026 (z. B. 90 €/tCO₂)

= €/t CBAM cost (hier ~51.53 €/t)

Various scenarios can be calculated for budgeting/pricing:

• CO₂ price (EUA) high/low
• Default vs real data
• Foreign CO₂ price (deduction) yes/no