CBAM guide
CBAM guide for exporters: what changes in 2026
The EU Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) puts a carbon price on certain goods imported into the EU. The importer pays – but the data has to come from you, the producer.
- 01.10.2023CBAM transitional period: quarterly reporting starts
- 01.01.2026CBAM definitive period: authorised declarant and certificates
- 01.07.2026EU DPP Registry live (API integration)
- 18.02.2027Battery passport mandatory for certain batteries
- 30.09.2027First annual CBAM declaration for 2026 imports
- 01.01.2034Free allocation fully phased out, CBAM at 100%
Which goods are covered?
Cement, iron and steel, aluminium, fertilisers, hydrogen and electricity – identified by CN code, including many downstream products such as screws, tubes and profiles.
Transitional vs definitive period
From October 2023 to the end of 2025 importers only reported quarterly. Since 1 January 2026 the definitive period applies: importers must be authorised CBAM declarants and surrender CBAM certificates for the embedded emissions of the goods they import each year.
How embedded emissions are calculated
Fuel combustion and process emissions of the installation, attributed to the product.
Embedded emissions of relevant input materials (e.g. pig iron, DRI, ferro-alloys, unwrought aluminium) – this is where supplier data matters.
Electricity consumed. Counted for cement and fertilisers; for iron & steel, aluminium and hydrogen they are reported but not priced in the definitive period.
SEE = (direct + Σ precursor qty × precursor SEE) / production (t)
Actual data vs default values
If you cannot provide verified actual data, default values set by the Commission are used – and they are designed to be conservative, with a mark-up that increases over the first years. Actual, verified data is usually the single biggest cost lever.
Free allocation phase-out
CBAM obligations are reduced to reflect free allocation still given to EU producers. That reduction shrinks every year until 2034:
| Year | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 | 2032 | 2033 | 2034 |
|---|---|---|---|---|---|---|---|---|---|
| CBAM share | 2.5% | 5% | 10% | 22.5% | 48.5% | 61% | 73.5% | 86% | 100% |
Carbon price paid at origin
A carbon price effectively paid in the country of production can be deducted. When the Turkish ETS starts pricing, this will directly reduce your customers' CBAM bill – if it is documented.
What exporters should do now
- 1Map every EU-bound product to its CN code and production route.
- 2Build the product → BOM → material → supplier graph for CBAM-relevant precursors.
- 3Collect installation-level energy and process data monthly (meters/SCADA), not annually.
- 4Request verified embedded-emission data from precursor suppliers – and keep the evidence.
- 5Calculate specific embedded emissions (tCO₂e/t) per product and period.
- 6Send your EU importers a consistent, auditable data package – before they ask.
- 7Model the € impact per product and customer for 2026–2034 and act on suppliers, scrap and energy.
Next wave: Digital Product Passport
Under the Ecodesign for Sustainable Products Regulation, product groups receive passports that carry sustainability and traceability data. The same product graph and evidence you build for CBAM feeds the DPP.
This guide is general information and simplifies the legal text. Benchmarks, default values and deadlines are defined in EU implementing acts – always check the current official sources.