CBAM

CBAM in 2026: what non-EU exporters need to know

The EU carbon border adjustment mechanism now applies in full. A plain guide for exporters of steel, aluminium, cement and fertilisers: what changes for you and what to prepare.

By Brahim Eloidii, Co-Founder, ESG & CSR Lead

Published 17 October 2026 · Sources last checked 16 October 2026

Where CBAM stands today

The carbon border adjustment mechanism (CBAM) puts a carbon price on certain goods imported into the EU, so that they carry a cost comparable to what EU producers pay under the EU emissions trading system. Its transitional reporting period ended on 31 December 2025. As of 1 January 2026, it applies under its definitive regime, with financial obligations for importers.

It covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Whether a product is covered depends on its customs (CN) code listed in Annex I of the Regulation, so the first job is always to map your products to their codes.

Who pays, and why exporters are still affected

The legal obligation sits with the EU importer, known as the authorised CBAM declarant. Each year the declarant reports the quantity of goods imported, their embedded emissions and the corresponding number of CBAM certificates, and surrenders those certificates. One certificate corresponds to one tonne of embedded CO2 equivalent, and its price follows the price of EU emissions allowances.

As an exporter you are affected because the embedded emissions of your goods set the importer’s bill. The importer needs data about your installation to calculate them, and an importer that cannot get reliable data has to fall back on default values.

The 50-tonne threshold

The 2025 simplification replaced the former exemption based on the value of a consignment with a single mass-based threshold: 50 tonnes a year, cumulated per importer, for cement, fertilisers, aluminium and iron and steel.

• It is an importer-level threshold. It is not set per supplier or per consignment.
• An importer that exceeds it becomes subject to all obligations for all covered goods imported that calendar year, not only for the excess.
• It does not apply to electricity or hydrogen.
• Above the threshold, imports generally require an authorised CBAM declarant or a qualifying indirect customs representative.

Default values or verified actual emissions

Importers may declare embedded emissions either on EU default values or on the actual emissions of the installation that made the goods. Actual data must be verified by an independent verifier accredited by an EU or EEA national accreditation body, and verification takes place at the level of the installation.

For an exporter this is the central choice. If you cannot supply verified data, your customers will declare on default values. If you can, you give them a lower, more certain figure to declare, and you have something concrete to show when they compare suppliers.

Dates to put in your calendar

What to do now

1. Map every product you ship to the EU to its CN code, and find out which ones are covered.
2. Ask each EU customer how they plan to declare your goods: on default values or on actual data, and what they need from you and by when.
3. Identify the installations that make the goods and set the boundaries of what is measured.
4. Gather fuel, electricity and production records for each installation, and the data from your input suppliers.
5. Write a monitoring plan and a calculation method that a verifier will accept.
6. Contact accredited verifiers early, because only verified data can replace default values.
7. Name an owner inside the company and set a budget and a timetable that ends before the first declaration.

The free CBAM Compass Report estimates your readiness against these checks and the cost per tonne your buyers may face on default values, in about three minutes.