The Carbon Border Adjustment Mechanism — CBAM — is the EU's carbon price at the border. From 1 January 2026, the definitive phase is in force: CBAM goods may only be released for free circulation by an Authorized CBAM Declarant (ACD). That affects any business importing steel, aluminium, cement, fertilisers or hydrogen from non-EU countries.
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If you import these goods above 50 tonnes per year, this page covers everything you need to understand your obligations: which products are in scope, how certificates are priced, what the fines are, and the seven practical steps to become compliant. If you are unsure whether your products fall under CBAM at all, start with the sector table and the 50-tonne threshold section.
CBAM Timeline: What Applied When, What Applies Now
| Date | Milestone | Status |
|---|---|---|
| 1 October 2023 | Transition period begins — quarterly reporting obligation | Passed |
| 1 January 2026 | Definitive phase starts — only ACDs may import CBAM goods | Active |
| 31 March 2026 | Transition deadline: importers who applied for ACD status by this date were permitted to continue importing CBAM goods while their application was under review (Regulation (EU) 2025/2083, transitional provision). Importers without an application filed by this date became subject to enforcement risk and potential penalties. | Passed |
| 7 April 2026 | Q1 2026 certificate price published: €75.36/tonne CO₂e | Passed |
| 6 July 2026 | Q2 2026 certificate price published | Upcoming |
| 1 February 2027 | Certificates go on sale via the CBAM registry | Upcoming |
| 30 September 2027 | First annual CBAM declaration (covering full year 2026) | Upcoming |
The definitive phase also introduced one major simplification: the Omnibus simplification package (Regulation (EU) 2025/2083, adopted 8 October 2025, published in the Official Journal on 17 October 2025, in force 20 October 2025) introduced a 50-tonne de minimis threshold. Importers below that threshold are exempt from registration and certificate obligations — with one exception: hydrogen and electricity have no threshold at all.
Which Sectors and Products Fall Under CBAM?
Current scope (2026)
| Sector | Indicative CN codes | 50-tonne exemption? |
|---|---|---|
| Iron and steel | 72xx, 7301–7326 (incl. CN 7318) | Yes |
| Aluminium | 7601–7616 (76xx) | Yes |
| Cement | 2523, 2507 40 | Yes |
| Fertilisers | 2808, 2814, 2834 21, 3102, 3105 | Yes |
| Hydrogen | 2804 10 00 | No — always obligatory |
| Electricity | 2716 00 00 | No — always obligatory |
What many importers overlook
Screws, bolts, and fasteners (CN 7318) are in scope. This is one of the most commonly missed categories — it is a finished product, but it falls under the iron and steel chapter and is within CBAM scope.
The 50-tonne threshold is cumulative across all CBAM goods. It is not calculated per product or per shipment, but as the total weight of all CBAM goods you import in a calendar year, per legal entity. 30 tonnes of steel plus 25 tonnes of aluminium equals 55 tonnes — above the threshold.
Indirect customs representation shifts responsibility. If a non-EU party imports through an indirect customs representative (freight forwarder), the representative bears the CBAM obligations — even when the goods are not imported on their own account.
Downstream expansion: not yet law
The European Commission has proposed extending CBAM to approximately 180 additional downstream steel and aluminium product lines (auto parts, household appliances, cables, construction materials). This proposal has not yet been adopted by the European Parliament and Council. Possible effective date: 2028. Exact scope and timeline remain uncertain.
The 50-Tonne Threshold: Is CBAM Relevant for You?
The simplest way to answer "does CBAM apply to me?" is to add up all CBAM goods you imported in the past calendar year.
Under 50,000 kg total
No ACD registration required. You are still required to include a Y127 code on your customs declaration (your freight forwarder handles this).
Over 50,000 kg total
CBAM obligations apply in full — you need ACD status and must eventually purchase certificates.
Hydrogen or electricity (any volume)
Excluded from the 50-tonne de minimis exemption.
Two things to check carefully: first, are you counting all CBAM CN codes together, not just your main product? Second, if your company imports on behalf of multiple clients, those volumes are aggregated at the importer level.
CBAM Certificate Price and What You Actually Pay in 2026
How the price is set
The CBAM certificate price is linked directly to the average closing price of EU Emissions Trading System (ETS) auctions. In 2026, the price is set per quarter (published after the quarter ends). From 2027, it will be published weekly.
The Q1 2026 CBAM certificate price is €75.36 per tonne CO₂e, published by the European Commission on 7 April 2026, based on average EU ETS auction closing prices for January–March 2026 (Commission Implementing Regulation (EU) 2025/2548).
| Quarter | Price | Publication date |
|---|---|---|
| Q1 2026 (Jan–Mar) | €75.36/tCO₂e | 7 April 2026 |
| Q2 2026 (Apr–Jun) | Not yet published | 6 July 2026 |
| Q3 2026 (Jul–Sep) | Not yet published | 5 October 2026 |
| Q4 2026 (Oct–Dec) | Not yet published | 4 January 2027 |
The phase-in factor: why 2026 costs are low
CBAM costs are phased in gradually from 2026 (2.5%) to 2034 (100%), in parallel with the phaseout of free ETS allocations.
| Year | Phase-in factor | Example: cost for 100 tonnes BF/BOF hot-rolled coil steel from China (2026) |
|---|---|---|
| 2026 | 2.5% | €284 (see calculation below) |
| 2030 | 27.5% | ~€3,100 |
| 2034 | 100% | ~€11,300 |
Worked example: 100 tonnes of BF/BOF hot-rolled coil steel from China (2026)
Using default emission values (no supplier data required):
Step 1 — Embedded emissions per tonne:
1.370 tCO₂e (default value for BF/BOF hot-rolled coil steel, Commission Implementing Regulation (EU) 2025/2621)
Step 2 — Certificate cost per tonne before markup:
1.370 × €75.36 = €103.24
Step 3 — Apply default value markup (+10% for 2026):
€103.24 × 1.10 = €113.57 per tonne
Step 4 — Apply phase-in factor (2.5% in 2026):
€113.57 × 2.5% = €2.84 per tonne
Step 5 — Total for 100 tonnes:
100 × €2.84 = €284
The 1.10 multiplier applies only when using default values. If you provide verified actual emissions data from your supplier, this markup does not apply. Note: 1.370 tCO₂e/t is the BF/BOF benchmark — the most carbon-intensive steel production route. Steel produced via electric arc furnace (EAF) using scrap has a default value of 0.072 tCO₂e/t, a factor 19 lower.
Conclusion for 2026: a typical SME importer of 100–500 tonnes of steel pays between €280 and €1,400 in certificates for the full year. The administrative burden — ACD registration, declaration, potential verification — is proportionally much heavier than the financial obligation in this first year.
Fines: What Happens If You Do Nothing?
The NEa (Netherlands Emissions Authority) has explicitly designated CBAM enforcement as a 2026 priority, stating (translated from Dutch): "In 2026, supervision and enforcement focus primarily on the import of CBAM goods without valid authorization." (NEa CBAM enforcement page, see also: NEa CBAM Intervention Policy 2026, published 17 December 2025)
The penalties below are split into EU-wide rules (applicable in all member states) and Dutch national implementation rules.
EU-wide penalties (Regulation (EU) 2023/956, Article 26)
| Violation | Fine |
|---|---|
| Insufficient certificates surrendered at annual declaration | €100 per tonne CO₂e in unsurrendered certificates (Article 26(1)) |
| Importing above the threshold without ACD status | 3 to 5 times the €100 amount, depending on duration, severity and intentional nature of the violation (Article 26(2)) |
| Failure to report during the transition period | €10–50 per tonne unreported CO₂e |
| Repeated or serious violations | Revocation of ACD authorisation |
Netherlands-specific: administrative fine caps (Dutch Environmental Management Act — Wet milieubeheer, September 2025 implementation bill)
| Company annual turnover | Maximum administrative fine per violation |
|---|---|
| Up to €4.5 million | €450,000 |
| Over €4.5 million | Up to 10% of annual turnover |
These caps apply to violations under Dutch national implementation law. Other EU member states may set different national cap levels in their own implementing legislation.
The most material risk for an importer who has done nothing is the combination of importing without ACD status plus accumulated missing certificates. At 3–5 times the standard rate, this adds up quickly for any volume above 50 tonnes.
7-Step Action Plan for Dutch and EU Importers
Determine whether you are above the threshold
Add up all CBAM CN-coded goods you have imported (or plan to import) in 2026 in kilograms. Under 50,000 kg: no ACD required. Over: proceed to step 2. Hydrogen and electricity: not covered by the 50-tonne exemption — proceed regardless of volume.
Arrange eHerkenning EH3
Access to the CBAM registry and the Dutch application portal (cbamtoelating.nl) requires eHerkenning at level EH3. Cost: approximately €50–150 per year per user. Processing time: 5–10 working days.
Apply for ACD status via the NEa
Apply via cbamtoelating.nl. Maximum processing time: 120 days. If you have not yet applied for ACD status, you cannot legally import CBAM goods above the 50-tonne threshold. The transitional import-continuity period that applied until 31 March 2026 has ended. Apply immediately — the NEa's 2026 enforcement priority is precisely this category of importer.
Choose your emission method
Default values: available without supplier data, with a markup (+10% for steel/aluminium/cement in 2026). No external verification required. Actual values: require a CBAM Communication Template from your supplier. No markup, lower costs. Requires verification by an accredited auditor from 2027.
Arrange a verifier (for your 2027 declaration)
The verifier market is limited in several EU member states. Indicative cost for SMEs: €2,000–€8,000 per audit. Start early — Q3/Q4 2026 is the right moment to contract one.
Purchase certificates (from 1 February 2027)
Purchase certificates through the CBAM registry from 1 February 2027. The quarterly requirement is that your account must hold certificates covering at least 50% of the total embedded emissions in all CBAM goods you have imported since the start of the year. At each quarter-end check, if your account falls below this threshold, you must purchase additional certificates.
Under the revised rules (Regulation (EU) 2025/2083), the repurchase limit for excess certificates is aligned with your actual annual purchase obligation. The previous one-third rule has been replaced.
Submit the annual CBAM declaration (before 30 September 2027)
The first financial settlement: submit certificates covering all 2026 imports. The Commission cancels the required certificates from your account.
Frequently Asked Questions
Certificates go on sale from 1 February 2027 via the CBAM registry (CBAM Registry). The certificates cover your full year 2026 imports. The first annual declaration — where you formally surrender the certificates — has a deadline of 30 September 2027. In 2026 itself you do not buy certificates, but you do need ACD status and must include the correct codes on every customs declaration.
An ACD is an EU-established importer who has received authorisation from the competent national authority (in the Netherlands: the NEa) to import CBAM goods in the definitive phase. Without ACD status, customs will block your CBAM goods at the border from 1 January 2026 onwards. You apply for ACD status via cbamtoelating.nl with eHerkenning EH3. Processing time is up to 120 days.
Yes. CN code 7318 (screws, bolts, nuts, rivets, washers) falls under the iron and steel chapter and is within the CBAM scope. Many importers of fixings and fasteners discover this later than expected. If you import these products from non-EU countries and your total CBAM volume exceeds 50 tonnes annually, you need ACD registration.
If your total CBAM goods imports in a calendar year stay below 50,000 kg, you are exempt from ACD registration and certificate obligations. You must still ensure the correct customs code appears on your declarations (Y127 for exempt importers). Your freight forwarder should handle this. Note: hydrogen and electricity have no threshold — they are always in scope regardless of volume.
For most SME importers, 2026 is the cheapest CBAM year there will ever be: the phase-in factor is 2.5%. Using the Q1 2026 certificate price of €75.36/tCO₂e and the default emission value for BF/BOF hot-rolled steel (1.370 tCO₂e/t), the certificate cost for 100 tonnes of steel is €284 for the full year. For 500 tonnes it is approximately €1,400. These are the direct certificate costs; the administrative costs (eHerkenning, possible verifier, accounting) will typically exceed the certificate cost in 2026.
Default values are standardised emission factors set by the European Commission per CN code and country of origin. They include a 10% markup (for steel/aluminium/cement in 2026). Any importer can use them without supplier data and without external verification. Actual values are real emission data from your specific supplier, provided via a CBAM Communication Template. They require verification by an accredited auditor (from 2027 onwards). For most SME importers, default values are the practical choice in 2026.
If a freight forwarder acts as indirect customs representative — meaning they declare goods in their own name on your behalf — the CBAM obligations rest with the forwarder, not with you as the buyer of the goods. If the forwarder acts as a direct customs representative (declaring in your name), the obligations remain with you as the importer. Clarify this arrangement with your logistics provider.
Check the CN code on your customs declarations against the CBAM product list. If the code starts with 72 or 73 (steel), 76 (aluminium), 2523 (cement), 28xx/31xx (fertilisers), or 2804 10 00 (hydrogen) — CBAM applies. CN 7318 (screws, bolts) is a common one that suppliers and forwarders sometimes miss. Use Import8's CBAM flag to verify your classification directly.
Check Whether Your Products Fall Under CBAM
Not sure if your specific products are in scope? Use the CBAM Calculator to get an instant estimate of your 2026 obligation based on your import volume and product type.
Want to check HS code and CBAM status in one step? Try Import8 — classify your product with AI and see immediately whether it carries a CBAM flag. Start with 5 free credits — no credit card required.
Sources
The following official sources form the basis for the claims on this page. Verification date: 18 May 2026.
- Regulation (EU) 2023/956 — CBAM base regulation (EUR-Lex)
- Regulation (EU) 2025/2083 — Omnibus simplification (EC TAXUD)
- Commission Implementing Regulation (EU) 2025/2548 — CBAM certificate price methodology (EC CBAM pricing page)
- Commission Implementing Regulation (EU) 2025/2621 — Default emission values (EUR-Lex)
- NEa CBAM Intervention Policy 2026 (emissieautoriteit.nl, published 17 December 2025)
- NEa — Supervision and enforcement CBAM (emissieautoriteit.nl)
- Carbon Border Adjustment Mechanism — European Commission DG TAXUD
- CBAM Registry and Reporting (European Commission)
Last verified: 18 May 2026. CBAM rules are evolving — always check official sources for the latest requirements before taking compliance decisions. This page is for informational purposes only and does not constitute legal or customs advice. Consult the NEa or a qualified customs expert for your specific situation.
