The EU Carbon Border Adjustment Mechanism left its transitional phase and entered its definitive regime on 1 January 2026. For anyone importing goods in scope, it changes two things: there is now a cost attached to embedded carbon, and there is a compliance role that somebody in the chain has to occupy.
In this piece
What is in scope
CBAM applies to imports of goods whose production is carbon-intensive and considered at risk of carbon leakage. The initial scope is cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, together with selected precursors. In June 2026 the Council agreed its negotiating position on the Commission's proposal to extend the mechanism to certain downstream goods and reinforce anti-circumvention safeguards. It is not adopted law yet, but the boundary is moving outward rather than settling.
For a minerals and specialities portfolio the exposure is narrow but real. It is the cement list rather than the aluminium list that catches a range like this — calcined clays (CN 2507 00 80), cement clinker (2523 10 00) and aluminous cement, including calcium aluminate cements (2523 30 00). Alumina and artificial corundum (CN 2818) are not listed at all, and the aluminium sector starts at unwrought metal (7601). The scope is defined by customs classification, not by product family, so the only reliable method is to check the CN codes on your actual import declarations against the CBAM goods list. Do not assume a grade is out of scope because it feels like a mineral rather than a metal.
The 50-tonne threshold
There is a single mass-based threshold of 50 tonnes of CBAM goods per importer per calendar year. Below it, the obligations do not bite. Cross it and they apply to everything imported that year, not only the excess — and an importer, or their indirect customs representative, must hold authorised CBAM declarant status.
This threshold shapes behaviour more than the carbon price does. A speciality additive imported in tens of kilos is nowhere near it. A bulk material in scope will pass it on a handful of loads. Many buyers will find they are either comfortably clear or clearly caught, with few sitting in between — which makes the assessment quick, and worth doing rather than assuming.
Authorised declarant status
Authorisation is applied for through the National Competent Authority in the Member State where the importer is established, via the Commission's Authorisation Management Module. It is not instantaneous, and it is a prerequisite for importing in-scope goods above the threshold — so it belongs on a project plan, not on a to-do list.
Declarants then report the emissions embedded in their imports and surrender the corresponding certificates annually. The first CBAM declaration is due by 30 September 2027, covering 2026 imports, with certificates surrendered at that point.
How certificates are priced
Certificates are sold by the Member States on a common central platform, and only from 1 February 2027 — 2026 liabilities are settled in arrears. They are priced off the EU Emissions Trading System allowance auction price, expressed in euros per tonne of CO₂. The averaging period tightens over time: a quarterly average during 2026, moving to a weekly average from 2027. The Commission published the first quarterly price in April 2026.
Where a carbon price has already been paid in the country of production, the corresponding amount can be deducted — which makes the producer's own carbon regime a commercially relevant fact about them, alongside price and lead time. Emissions may be declared using verified actual values or applicable default values; actuals require verification but will usually favour an efficient producer.
Why the importer of record matters
This is the practical consequence for purchasing, and it echoes the REACH logic exactly. CBAM obligations attach to the importer. Buying the same tonne of the same material from the same producer produces a completely different compliance position depending on who brings it across the border.
- Buy EXW or FCA from a non-EU producer and you are the importer. Registration, reporting, verification and certificate purchase are yours, and the tonnage counts toward your 50-tonne threshold.
- Buy from a distributor established in the EU, who has already imported and cleared the material, and you are buying goods in free circulation. The CBAM obligation sat with them.
Neither is inherently better. The first can be cheaper per tonne; the second removes an administrative and reporting burden and keeps you below a threshold. What matters is that it is now a deliberate decision with a cost attached, rather than a shipping-terms detail settled by whoever booked the freight.
What to do now
- Pull twelve months of import declarations and check the CN codes against the CBAM goods list. Identify tonnage per code.
- For anything in scope, work out whether you clear 50 tonnes a year across all CBAM goods — it is one threshold, not one per product.
- If you do, start the authorised declarant application now; the first declaration deadline is September 2027 but authorisation is a prerequisite for importing.
- Ask your non-EU producers whether they can supply verified actual emissions data, and whether a carbon price is already paid at origin.
- Review Incoterms on in-scope imports. Buying from an EU-established supplier moves the obligation; DDP only does so where the seller is itself EU-established or clears through an EU indirect customs representative, because the declarant must be established in the EU. Price that against the per-tonne difference.
- Watch the downstream-goods extension: the Council agreed its negotiating position in June 2026, and if adopted it will pull additional products into scope.
Regulatory summary as at July 2026, based on the European Commission's published CBAM guidance. This is not legal or customs advice — confirm your own classification and obligations with your customs representative.
