CBAM 2026 FAQ: Goods, Thresholds, Reporting & Certificate Costs

As of January 1, 2026, the CBAM Regulation (EU 2023/956) has entered into force. The affected product groups include cement, iron and steel, aluminium, fertilizers, electricity, and hydrogen. For cement, iron and steel, aluminium, and fertilizers, an annual threshold of 50 tons applies—once this is exceeded, registration as an authorized CBAM declarant is required. Electricity and hydrogen are subject to CBAM regardless of the imported quantity. The 50-ton threshold refers to the total volume of all CBAM-relevant goods imported by one importer within a calendar year. If the aggregated annual quantity exceeds 50 tons, CBAM obligations apply. Below, you will find answers to the key questions on the CBAM Regulation from 2026 onwards.

Which goods and quantities are subject to CBAM?

The CBAM Regulation applies to common customs tariff codes (CN codes), which add two digits to the HS code and are used as commodity codes for exports outside the EU. The product groups currently affected are steel & iron, aluminium, cement, fertilizers, electricity, and hydrogen. All goods for which embedded emissions must be reported are listed in the annex to the CBAM Regulation. These are referred to as “CBAM goods.”

If you import more than a total of 50 tons of CBAM goods into the EU in a calendar year, you are subject to CBAM. The total annual quantity of all CBAM goods is relevant here, even if you are below the 50-ton limit for a single product. The 50-ton limit does not apply to electricity and hydrogen: if you import either of these two goods, you are always subject to CBAM.

What changes with the start of the CBAM definitive regime in 2026?

The most important changes with the definitive regime from January 1, 2026, onwards are the start of annual reporting and the obligation to purchase CBAM certificates. CBAM certificates can be purchased from the beginning of 2027 and must be purchased retroactively for the year 2026. The first CBAM declaration for 2026 is due on September 30, 2027.

In addition, you must ensure that you obtain the status of Authorized CBAM Declarant in order to be allowed to import more than 50 tons per year of CBAM goods or hydrogen or electricity into the EU.

What are the reporting requirements? When do I have to submit a CBAM report?

During the transition period (October 1, 2023, to December 31, 2025), you had to submit a CBAM report on a quarterly basis. With the start of the CBAM definitive regime on January 1, 2026, you must submit a CBAM report annually, always by the end of September of the following year for the previous year. This means that the report for 2026 is due on September 30, 2027. This report must contain information about the CBAM goods you imported in the previous year, their embedded emissions, and the total number of CBAM certificates you purchased.

How can I calculate my CBAM certificate costs?

The CBAM certificate costs depend on the number of certificates you need to purchase and the CBAM certificate price. In 2026, the CBAM certificate price will be set quarterly, and from 2027 onwards, it will be set weekly, always based on the average price of a European emissions trading certificate (EU ETS).

The number of certificates can be calculated using the following formula:

What are CBAM default values and how do they work?

The default values for CBAM goods are values that can be used for reporting embedded emissions when verified actual data is not available. The new default values for the definitive regime from December 16, 2025, are available per CN code and country, with the option “Other Countries and Territories” if no default values are listed for a specific country or CN code.

What are CBAM Benchmarks and the Phase-in Factor?

The CBAM benchmark is a EU reference value for the amount of CO2 emissions per CBAM good (CN code) if the good was produced by an efficient EU producer. It is multiplied with the phase-in factor and through that reduces the embedded emissions and number of CBAM certificates that you need to buy annually. As the phase-in factor decreases every year until it reaches 0% in 2034, the CBAM costs will increase and in 2034, 100% of your embedded emissions will be subject to CBAM costs.

What are direct and indirect emissions?

Direct emissions cover the emissions generated during the production processes of CBAM goods, including from the production of heating and cooling, irrespective of the location of the production of the heating and cooling. This means that when the production of heating and cooling takes place outside the installations, the resulting emissions are counted as direct emissions.

Indirect emissions cover the production of electricity that is consumed during the production of CBAM goods.

In the definitive regime, importers of iron & steel, aluminium, hydrogen and electricity only need to report on direct emissions. Importers of cement and fertilizers need to report on both direct and indirect emissions.