CBAM for importers: what the 2026 definitive period means for you

What CBAM is, in plain words

The Carbon Border Adjustment Mechanism, set up by Regulation (EU) 2023/956, puts a carbon price on certain imported goods equal to what an EU producer pays under the EU Emissions Trading System. The idea is that a steel coil made in Hebei and one made in Germany carry the same carbon cost when sold in the EU. The cost is calculated on the embedded emissions of the goods, meaning the greenhouse gases released when they were produced, and is paid by the EU importer, not by the Chinese supplier. A transitional period with reporting only ran from October 2023 to December 2025. The definitive period, with real payments, started on 1 January 2026. The charge phases in as free allowances for EU producers are reduced between 2026 and 2034, so the share actually paid starts small and rises each year.

Which goods are covered

Transitional period vs definitive period

The CBAM timeline at a glance

1. 1 October 2023Transitional period starts: quarterly reporting only.
2. 31 December 2025Transitional period ends.
3. 1 January 2026Definitive period starts; authorisation needed above the threshold.
4. 31 March 2026Importers that applied for authorisation by this date could keep importing while their application was decided.
5. April 2026The Commission published the first quarterly certificate price, €75.36 per tonne for Q1 2026.
6. February 2027CBAM certificate sales open on the common central platform.
7. 30 September 2027First annual CBAM declaration for 2026 imports and surrender of certificates.
8. 31 October 2027Deadline to ask for repurchase of surplus certificates.

Who has to do what

The legal obligation sits with the authorised CBAM declarant. That is normally the EU importer of record. An importer established outside the EU, for example a Gulf trading company selling steel products to EU buyers, cannot simply ship and pay: it works through an indirect customs representative in the EU who holds the authorisation, under the same deadlines. Authorisation is requested in the CBAM Registry, and customs check the authorisation on the import declaration before releasing CBAM goods for an importer above the threshold. The declarant must record the emissions of each consignment, buy enough certificates, file the annual declaration and keep the supporting data. Missing obligations can lead to substantial penalties, so CBAM belongs in the purchase decision, not after arrival.

Emissions data from Chinese suppliers

The number of certificates depends on the embedded emissions per tonne of product. You can use actual emissions reported by the producing installation and checked by an accredited verifier, or default values set by the Commission. Default values are deliberately conservative and can be high, so a Chinese mill or smelter that can provide verified installation data usually lowers your cost. Ask early: the supplier needs the installation identity, production route, and emissions of the specific goods, plus any carbon price effectively paid in the country of origin, which can be deducted under conditions. Put the obligation to provide this data in the purchase contract.

What your forwarder needs from you

CBAM rules are still being refined, including simplifications agreed in 2025 and implementing acts on certificates and the central platform. We check the current rules for every shipment. Golden Way moves cargo from China to Turkey and Europe by the Middle Corridor and TIR trucks and quotes within one working day. See also our guide to importing into the EU from China for EORI, ICS2 and VAT.

Frequently asked questions

General information checked on the date shown. Rules and rates change: our team confirms the details for your shipment.