CBAM is paid by the European importer. You, as a producer outside the European Union, file no declarations and buy no certificates. What reaches you is a request: the emissions of your product, calculated with the European method and verified.
Answering that request is voluntary. Not answering has a cost that ends up in the price of your product. This guide explains why, using the dates and rules the European Commission had published as of October 10, 2026.
What it is and who it reaches
The Carbon Border Adjustment Mechanism (CBAM) puts a price on the emissions embedded in certain products entering the European Union. It was created by Regulation (EU) 2023/956, amended in 2025 by Regulation (EU) 2025/2083.
It covers six sectors: iron and steel, cement, fertilisers, aluminium, hydrogen and electricity.
From 2023 to 2025 there was a transitional period in which importers only reported. Since January 1, 2026 the definitive regime applies, with a payment obligation.
There is an exception by volume. An importer bringing in less than 50 tonnes of CBAM goods a year does not need an authorisation. It does not apply to hydrogen or electricity. If your buyer imports volumes that small, it may never ask you for anything and the rest of this guide will be of little use to you for now.
The Commission has also tabled a proposal, COM(2025) 989, to extend the mechanism to products made from these materials. It was still in the legislative process when this guide was written.
The dates
| Date | What happens |
|---|---|
| January 1, 2026 | The definitive regime starts. The importer must be an authorised CBAM declarant |
| February 1, 2027 | CBAM certificate sales begin, including for 2026 imports |
| September 30, 2027 | First annual declaration and surrender of certificates, for 2026 imports |
| Every quarter from 2027 | The importer must hold certificates for at least 50% of the emissions imported that year |
| 2034 | Free allocation of allowances in the European system ends for these sectors |
That last row explains why the cost rises over the years. While European producers still receive free allowances, CBAM applies only to the share of emissions not covered by them. As that allocation shrinks, the share the importer pays grows.
What a certificate costs
The price follows European emission allowances. For 2026 the Commission publishes it by quarter: EUR 75.36 in the first, EUR 75.28 in the second and EUR 82.32 in the third. From 2027 it is calculated weekly.
What your buyer will ask for
Embedded emissions per tonne of product, calculated under the CBAM methodology. The scope depends on the sector:
- For iron and steel, aluminium and hydrogen, direct emissions are declared.
- For cement and fertilisers, both direct and indirect emissions are declared.
In both cases the emissions of precursors are added. Precursors are the CBAM-covered materials you use to make your own product. Clinker in cement is the typical example.
The Commission publishes an Excel template for the calculation. It has a worksheet called Summary_Communication that gathers what the importer needs. Using it is not compulsory, but it is what your buyer expects to receive.
You can also register as a third-country operator in the CBAM Registry, with access through the Commission's EU-Access platform. In 2027 this is not required: you can send the information directly to your buyer, who uploads it with the declaration.
What happens if you provide no data
The importer uses default values. They are set by country and by product, and a mark-up is added: 10% in 2026, 20% in 2027 and 30% from 2028. For fertilisers the mark-up is 1%.
The Commission itself says that in most cases actual values should be more advantageous than default values.
With default values, importing your product costs your buyer more than importing from a competitor who does provide data. The gap widens every year, because of the mark-up and the shrinking free allocation. Sooner or later that gap shows up in the price negotiation, or in the decision about who to buy from.
Verification
Actual emissions for goods imported from January 1, 2026 must be verified by an accredited CBAM verifier. You can hire any verifier holding that accreditation, and the list is published in the CBAM Registry.
The Commission expects the first verification reports in early 2027.
A warning that comes from the Commission itself: the importer should only receive verified data from the operator that produced the goods. If a third party offers your buyer a verification report on your products, it is probably a scam.
If you already pay a carbon price
The regulation lets the importer deduct the carbon price effectively paid in the country of origin for the declared emissions. What counts is what was really paid: any rebate or compensation is subtracted.
The Commission said in May 2026 that it planned to adopt an implementing act that year with the detail: how the amount is converted to euros, what evidence of payment is required and how it is certified.
We found no official statement on Chile's green tax or on other carbon prices in Latin America. Until those rules exist, we would not count on the deduction in any negotiation.
Penalties
They fall on the importer. National authorities may sanction it if its declaration contains errors. That is why European buyers are asking for verified data and adding clauses to their contracts: the risk is theirs and they pass it back.
Where to start
- Confirm whether your products are covered. Ask your buyer for the customs code it imports them under.
- Ask what volume it imports per year. Below 50 tonnes it needs no authorisation.
- Measure the emissions of the installation that makes those products. The CBAM methodology works by installation and by product, in more detail than a corporate footprint.
- Identify your precursors and ask those suppliers for their data. Without it you will have to use default values for that part.
- Get verification quotes early. The first reports are issued in early 2027 and the first declaration is due on September 30.
If you already have a corporate footprint, start there. The CBAM calculation asks for more detail, but the plant's consumption data is already gathered and backed by evidence.
Where Grumbic fits
Grumbic gathers your operation's energy and fuel data from your invoices and keeps every figure linked to its document. That is the base you need before moving to the per-product calculation CBAM asks for.
See the platform or talk to us.
Sources
Information reviewed on October 10, 2026 on the European Commission's sites. This guide is informational and does not replace legal or customs advice.
