Authorised CBAM declarant
Applies for authorisation, declares embedded emissions each year, buys and surrenders certificates. Below 50 tonnes a year, exempt.
EU · Carbon · Regulation (EU) 2023/956
CBAM: verified emissions data, straight from the mill.
Since 1 January 2026, EU importers of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen pay for the emissions embedded in those goods by surrendering CBAM certificates. For suppliers in India and China, the practical ask is verified, installation-level emissions data; without it, importers use EU default values, which include a mark-up that rises every year to 2028.
- 1 Jan 2026
- definitive period began
- 50 t
- annual exemption threshold
- 30 Sep 2027
- first declaration and surrender
Status · checked 28 Sep 2026 Definitive since 1 Jan 2026
- Definitive period begins
- Authorisation applications for provisional import
- 28 Sep 2026
- Q3 2026 certificate price published
- Certificate sales open
- First annual CBAM declaration and surrender
- Free allocation fully phased out
The short answer
What you need to know.
Checked against official sources on 28 September 2026.
- 01
The definitive CBAM regime has applied since 1 January 2026. It brings authorisation, an annual declaration, and the purchase and surrender of CBAM certificates for embedded emissions (Regulation (EU) 2023/956).
- 02
Goods covered: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, listed by CN code in Annex I. That includes downstream steel articles such as screws, bolts and nuts.
- 03
Importers bringing in 50 tonnes or less of CBAM goods (net, all CN codes) in a calendar year are exempt, except for electricity and hydrogen. Above that, only an authorised CBAM declarant may import (Regulation (EU) 2025/2083).
- 04
The first annual declaration and certificate surrender for 2026 imports are due by 30 September 2027. Certificate sales open on 1 February 2027. The 2026 price is the quarterly EU ETS average: €75.36 (Q1) and €75.28 (Q2) per tonne of CO2e.
- 05
Actual embedded emissions declared must be verified by an accredited verifier (Art. 8). Actual supplier data usually beats the EU default values, which include a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 for steel, aluminium and cement.
Who it applies to
The declarant files. The mill supplies the data.
Mills, smelters and fabricators
Installations in India, China or Vietnam that produce the goods. They provide emissions data per installation and production route, ideally verified.
Brokers and indirect representatives
Can act for the importer at the border; the declarant’s duties still need the supplier’s emissions data.
Brands buying steel-intensive products
Parts made of steel or aluminium may already be in Annex I. A proposal to add 180 downstream products is under negotiation (proposed).
Key dates
Every date, with its source.
Only dates set in law or official publications. Anything still proposed is marked as proposed.
-
CBAM simplification published
Regulation (EU) 2025/2083 introduces the 50-tonne exemption and moves the first declaration to 30 September 2027.
-
Default values published
Default embedded emissions by CN code and country of origin, including the yearly mark-up.
-
Definitive period begins
Authorisation, reporting and certificate obligations apply. The CBAM factor phasing out EU free allocation starts at 97.5%.
-
Authorisation applications for provisional import
Importers above the threshold who applied by this date may keep importing until the authority decides.
-
Q1 2026 certificate price: €75.36
-
Q2 2026 certificate price: €75.28
-
Downstream extension: Parliament committee report
ENVI adopted its report on extending CBAM to 180 downstream steel and aluminium products (COM(2025) 989). Plenary vote scheduled for September 2026, then negotiations with the Council.
- Today · 28 September 2026
-
Q3 2026 certificate price published
-
Q4 2026 certificate price published
From 2027 the price becomes a weekly average of EU ETS auction prices.
-
Certificate sales open
Member States sell certificates on the common central platform. From 2027, declarants hold certificates for at least 50% of embedded emissions at the end of each quarter.
-
First annual CBAM declaration and surrender
Declaration for 2026 imports, and surrender of certificates for 2026 embedded emissions. Then every 30 September for the previous year.
-
Free allocation fully phased out
No CBAM factor applies from 2034, so the free allocation deduction ends.
Why supplier data matters
Default values rise. Free allocation falls.
Two schedules set in law push CBAM costs up each year. Verified data from your supplier is how you keep them in check.
EU default values for two common parts
Tonnes of CO2e per tonne of product, from Implementing Regulation (EU) 2025/2621. Values including the mark-up for each year.
| Product and origin | Base | 2026 | 2027 | 2028+ |
|---|---|---|---|---|
| Threaded screws and bolts (CN 7318 15), India | 5.720 | 6.292 | 6.864 | 7.436 |
| Threaded screws and bolts (CN 7318 15), China | 6.375 | 7.013 | 7.650 | 8.288 |
| Aluminium profiles (CN 7604 10 90), India | 3.444 | 3.788 | 4.132 | 4.477 |
| Aluminium profiles (CN 7604 10 90), China | 4.881 | 5.369 | 5.857 | 6.345 |
Mark-up: 10% in 2026, 20% in 2027, 30% from 2028 (1% for fertilisers). Verified actual values replace these.
CBAM factor: free allocation still deducted
Share of the benchmark-based free allocation still reflected in the certificates due. As it falls, more emissions are paid for.
Directive 2003/87/EC Art. 10a(1a), as amended by Directive (EU) 2023/959.
What you need from suppliers
What to ask your mill or foundry.
Most Indian and Chinese suppliers can produce this data with help. We sit with their teams and collect it on site.
- Installation and production routeWhich plant made each lot, and the route (for example blast furnace or electric arc furnace), per CN code.
- Embedded emissions per tonneDirect emissions, and indirect emissions where relevant, calculated with the EU methodology for each good.
- Precursor dataWhere the plant bought billets, slabs or primary aluminium, their origin and embedded emissions.
- Verification by an accredited verifierActual emissions declared must be verified (Art. 8). Ask whether the installation is registered and has verified data.
- Carbon price paid at originEvidence of any carbon price effectively paid in the country of production, which can reduce the certificates due.
- Net mass per shipment and CN codeTonnages that reconcile with invoices and customs entries, for the 50-tonne test and the declaration.
How SourceSquid helps
From your product list to an audit-ready file.
Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.
- 01
Exposure scan
Your purchases mapped to CN codes and tonnes per year, with the 50-tonne test and the goods already in Annex I.
You receiveCBAM exposure map - 02
Supplier onboarding
Data templates explained to plant teams in Hindi, Tamil, Kannada, Mandarin and more, with a named contact per installation.
You receiveSupplier data plan - 03
On-site data collection
Energy, fuel, production and precursor records gathered at the mill or foundry and checked for consistency.
You receiveInstallation data pack - 04
Verification support
Documents organised for the accredited verifier, with questions answered by our engineers.
You receiveVerification-ready file - 05
Declaration dataset
Embedded emissions by CN code, installation and quarter, ready for your declarant or customs representative.
You receiveDeclaration-ready dataset - 06
Cost and sourcing view
Actual versus default values compared, and lower-emission suppliers identified where it pays.
You receiveCBAM cost comparison
Sources
Official texts behind this page
Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.
- Regulation (EU) 2023/956 establishing a carbon border adjustment mechanismAnnex I (goods); Art. 8 (verification); Art. 9 (carbon price paid)
- Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 (simplification)Art. 2a and Annex VII (50-tonne threshold); Arts. 6, 17, 20, 22 as amended
- Commission Implementing Regulation (EU) 2025/2621: default valuesAnnex I; mark-ups by year
- Commission Implementing Regulation (EU) 2025/2620: free allocation adjustment
- Commission Implementing Regulation (EU) 2025/2548: certificate price
- Directive (EU) 2023/959 amending the EU ETS Directive: CBAM factorDirective 2003/87/EC Art. 10a(1a)
- European Commission: price of CBAM certificates
- European Commission: Carbon Border Adjustment Mechanism
- European Parliament Research Service: CBAM extension to downstream productsCOM(2025) 989: proposed, not law
Related compliance guides
Rules that often travel together.
EU · deforestationEUDRDeforestation Regulation: due diligence statements and plot geolocation for seven commodities.→EU · reportingCSRD and Scope 3Sustainability reporting after the 2026 Omnibus, and the value chain cap for suppliers.→Weekly updatesCompliance RadarRecent and upcoming rule changes, dated and sourced.→
CBAM questions
Straight answers.
Dates checked against official sources. We update this page when the rules move.
anirudh@sourcesquid.coDoes CBAM apply to Indian and Chinese steel exporters?
CBAM obligations sit with the EU importer, who must be an authorised CBAM declarant above the 50-tonne threshold. Mills and fabricators in India or China are not declarants, but they are asked for the verified, installation-level emissions data that lets their EU customer declare actual values instead of EU default values, which carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 for steel.
Is there a CBAM threshold for small importers?
Yes. Since Regulation (EU) 2025/2083, an importer is exempt when the total net mass of CBAM goods it imports in a calendar year is 50 tonnes or less, across all CN codes. Once the threshold is exceeded, all CBAM goods imported that year are covered. The exemption does not apply to electricity or hydrogen.
When is the first CBAM declaration due?
The first annual CBAM declaration, covering goods imported in 2026, is due by 30 September 2027. Certificates for 2026 embedded emissions are surrendered by the same date. Member States start selling certificates on the common central platform on 1 February 2027.
How much does a CBAM certificate cost?
One certificate covers one tonne of CO2e. For 2026 imports the price is the quarterly average of EU ETS auction clearing prices for the quarter of import: €75.36 for Q1 2026 and €75.28 for Q2 2026. The Q3 price is due on 5 October 2026 and the Q4 price on 4 January 2027. From 2027 the price is a weekly average.
Are fasteners and other finished steel products covered by CBAM?
Many already are. Annex I of Regulation (EU) 2023/956 includes downstream iron and steel articles such as screws, bolts, nuts and washers (CN 7318) and other articles of iron or steel (CN 7326), as well as aluminium bars, rods, profiles and wire. A December 2025 proposal (COM(2025) 989) would add 180 more steel- and aluminium-intensive downstream products; it is not yet law.
Start here
Actual emissions data beats default values.
Tell us which steel or aluminium parts you import and from where. We return your CBAM exposure and a plan to collect verified data from each supplier.