EU CBAM for Exporters: 2026 Rules, the 50-Tonne Threshold and the Emissions Data Buyers Ask For

What CBAM is and which goods it covers

CBAM is the EU's charge on the greenhouse gas emissions embedded in certain imported goods, set up by Regulation (EU) 2023/956 so that imports pay a carbon price comparable to the one EU producers pay under the EU Emissions Trading System (EU ETS). It covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, including some downstream products such as certain steel and aluminium articles. The exact goods are listed by Combined Nomenclature (CN) code in Annex I to the Regulation; check your 8-digit CN code there or in the EU's TARIC database.

From October 2023 to the end of 2025 CBAM ran in a transitional period with reporting only. The definitive period, with authorisation, certificates and annual declarations, started on 1 January 2026.

The 50-tonne threshold and authorised CBAM declarants

Regulation (EU) 2025/2083, in force since 20 October 2025, simplified CBAM. Its main change is a single threshold: an importer that brings in less than 50 tonnes net mass of CBAM goods in a calendar year is exempt from CBAM obligations. The European Commission expects this to exempt about 182,000 importers while keeping more than 99% of the emissions covered. Hydrogen and electricity are not covered by the threshold and are subject to CBAM in any quantity.

An importer that will reach 50 tonnes must hold the status of authorised CBAM declarant, and should apply before it reaches the limit. Importers that applied by 31 March 2026 could keep importing while their application was processed. The applicant must be established in an EU Member State; if the importer is not, its indirect customs representative must apply. So if you sell DDP and act as the importer yourself, CBAM is your obligation, through an indirect customs representative who holds the authorisation.

Certificates and deadlines

• CBAM certificates are bought on a common central platform linked to the CBAM Registry, from February 2027.
• For goods imported in 2026, the certificate price is the average of the EU ETS auction clearing prices for the quarter of import. The Commission published EUR 75.36 for the first quarter of 2026 and EUR 75.28 for the second. From 2027 it publishes weekly prices.
• From 2027, an authorised declarant above the threshold must hold, at the end of each quarter, certificates for at least 50% of the emissions embedded in the CBAM goods it has imported since the start of the year.
• By 30 September of each year the declarant submits the annual CBAM declaration for the previous year's imports and surrenders the matching number of certificates. The first declaration, for 2026, is due by 30 September 2027.
• Excess certificates can be repurchased if requested by 31 October of the year in which certificates were surrendered.

What exporters outside the EU should prepare

The obligations fall on the EU importer, but the emissions data comes from the producer. EU Commission guidance asks operators of installations outside the EU to:

• Create an EU Login account and register their installations in the operator portal of the CBAM Registry.
• Monitor and calculate the emissions of each installation and the emissions embedded in each CBAM product, following the EU calculation rules.
• Contact an accredited CBAM verifier: the first verifiers are expected to be accredited by the end of 2026 and verification of emissions to start in early 2027.
• Share the verified data with their EU buyers, who need it for the annual declaration. Without actual verified data, the declarant may use the default values published by the Commission.
• If a carbon price is paid in the country of production, keep the evidence: CBAM allows a reduction for it, and from 2027 the Commission may publish default carbon prices for third countries that have carbon pricing.

On the invoice and in the contract

Show the 8-digit CN code and the net mass of each CBAM product on the commercial invoice and packing list, so that the buyer can check the threshold and declare correctly. Agree in the sales contract who provides emissions data and by when, and who bears the CBAM cost. Under DDP the seller is the importer, so the CBAM obligation and cost sit with the seller; under the other Incoterms rules the EU buyer, as importer, carries them and will usually reflect them in its price negotiations.