Navigating the EU’s CBAM

• Active carbon cost: Importers of goods like iron, steel, aluminium, cement, fertilisers, hydrogen, and electricity now face direct financial responsibilities for emissions. 

• First official price: On 7 April 2026, the European Commission announced the first quarterly CBAM certificate price at €75.36 per tonne of CO2, based on the average EU Emissions Trading System (ETS) auction prices from Q1 2026. 

• Authorised declarant status: EU importers of over 50 tonnes of CBAM goods annually needed to apply for "authorised CBAM declarant" status by 31 March 2026. 

• Registration enforcement: From January 2026, customs authorities began real-time validation of these authorisations at EU borders. Importers without a valid CBAM account number may face shipment delays or refusal to clear goods.  

• Reporting cycles: While emissions are currently tracked, the first annual declaration and certificate surrender for 2026 imports are due on 30 September 2027. 

To ease administrative burdens, especially for SMEs, the EU has adopted the Omnibus simplification package: 

• De minimis exemption: Importers bringing in less than 50 tonnes annually across all covered sectors are now exempt from registration and certificate requirements.  

• Extended deadlines: The deadline for submitting the first annual reports in 2027 has been moved to 30 September to allow more preparation time. 

The European Commission has proposed extending CBAM to 180 additional downstream products, such as steel and aluminium-intensive manufactured goods, starting 1 January 2028. This aims to prevent ‘carbon leakage’ by importing finished parts instead of raw materials to avoid the CBAM implications. 

• Credit for foreign carbon prices: Importers can deduct any verified carbon price already paid in the country of origin, like the UK or China's national carbon markets, from their EU liability. 

• Accreditation cooperation: Recent agreements, such as one between Ukraine and Sweden in April 2026, are simplifying the accreditation of third-party verifiers to speed up data validation for exporters.