The Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026. Reporting alone no longer covers it: importing CBAM goods — iron and steel, aluminium, cement, fertilisers, electricity and hydrogen — above the threshold now requires the status of authorised CBAM declarant.
The 50-tonne threshold
The Omnibus revision (Regulation (EU) 2025/2083) introduced a de minimis of 50 tonnes of CBAM goods per importer per calendar year. Stay below it and the CBAM obligations don't apply; this exempts roughly 90% of importers while keeping about 99% of embedded emissions in scope. The threshold does not apply to electricity and hydrogen. Bear in mind that the 50 tonnes count across all your CBAM imports combined, so a handful of mixed shipments with steel or aluminium parts can cross it sooner than you'd think.
The dates ahead
- 1 February 2027 — the sale of CBAM certificates starts (moved from 1 January 2026 by the Omnibus).
- 30 September 2027 — the first CBAM declaration is due, covering goods imported in 2026, together with the surrender of certificates.
- For 2026 imports the certificate price follows the quarterly average auction price of EU ETS allowances; the first price was published on 7 April 2026. From 2027 it switches to a weekly average.
Authorisation: the queue is now
Importers who applied for authorisation by 31 March 2026 may keep importing while their application is processed. Apply later and you cannot import above the threshold until the status is granted, so a pending application is not a free pass anymore. In the Netherlands the application runs via the CBAM Registry, with the NEa (Nederlandse Emissieautoriteit) as competent authority.
What this means for you
Three things to sort out in the second half of 2026: check whether your CBAM imports will pass 50 tonnes this year and apply for authorisation if you haven't; start collecting actual emissions data from your suppliers for the 2026 declaration; and budget the certificate cost into your 2027 purchase prices, because from February 2027 carbon becomes a real line item on imports. Background, scope and tariff codes are on our knowledge-base page: CBAM.
Source: European Commission — Carbon Border Adjustment Mechanism · EUR-Lex — Regulation (EU) 2025/2083.