EU CBAM in 2026: what importers and non-EU suppliers should prepare

Check the goods before assuming the rules apply

The European Commission lists cement, iron and steel, aluminium, fertilisers, electricity and hydrogen as the initial CBAM sectors. Coverage depends on the specific goods and customs codes in the legislation, not simply a company’s industry label. A business selling metal-containing products should check the exact product code rather than assume every item is covered.

The Commission’s definitive-regime page explains the regime’s start date and the importer’s annual emissions and certificate obligations [1]. Check the current legal scope, origin rules and any applicable exemptions with your customs adviser.

The 50-tonne threshold is not universal

For the mass-based threshold, the Commission states that EU importers—or their indirect customs representatives—importing more than 50 tonnes of CBAM goods must apply for authorised CBAM declarant status [1]. Treat this as an annual importer-level question, not a separate allowance for every shipment or supplier.

The Commission’s quick guide expressly excludes electricity and hydrogen from that mass-based threshold [3]. Do not extend the 50-tonne exemption to those products. Monitor cumulative covered imports and confirm exactly how the legislation applies to your purchasing entity and goods.

Who does what: importer versus producer

The EU compliance obligation belongs to the authorised declarant, which may be the importer or an eligible indirect customs representative. A non-EU supplier does not become the EU declarant simply by exporting goods. Agree who is responsible for customs and CBAM compliance before committing to delivery terms.

Non-EU installation operators provide production and embedded-emissions information that supports the importer’s declaration. The Commission published guidance for definitive-period implementation on 14 August 2026. Where actual emissions values are used, the Commission describes independent verification by appropriately accredited verifiers; default values follow the applicable rules and are not an invitation to invent a figure.

Ask for evidence early in the RFQ

Before award, agree the data owner, format, reporting period and delivery date. Requirements depend on the product and production process; the following list is a starting point, not a complete emissions methodology.

• Precise product description, proposed customs code, quantity and country of origin.
• Identity and location of the producing installation, not just the trading company.
• Applicable production-route and embedded-emissions information, prepared under the relevant methodology.
• Verification evidence where actual emissions values require it.
• Evidence of any carbon price effectively paid that the importer intends to claim under the applicable deduction rules.
• A named contact to resolve missing data and document revisions.

Do not invent a flat CBAM surcharge

The Commission states that certificate prices are linked to EU Emissions Trading System auction prices, using a quarterly average in 2026 and a weekly average from 2027 [1]. This is not a universal percentage to add to every supplier quote.

Actual exposure depends on the goods, quantities, embedded emissions and applicable adjustments. If a quote includes a CBAM-related allowance, ask for its assumptions and specify who bears changes. Do not present an estimate as a confirmed government charge or assume the 2026 start means every payment and declaration is due immediately.

A practical next step for buyers and suppliers

Buyers should map covered purchases and confirm declarant status, data requirements and current deadlines. Suppliers should identify the producing installations and test whether they can supply the requested evidence before promising a delivery price.

On Quotendra, put the information requirements in the RFQ and use the private request thread to clarify gaps. Use confidentiality protections where needed, but do not publish proprietary production data on a public profile. Quotendra does not calculate CBAM liability or certify emissions compliance; follow the current Commission guidance and obtain qualified advice for the transaction.