The Carbon Border Adjustment Mechanism (CBAM) entered its definitive period on 1 January 2026. But the 2025 CBAM Omnibus simplification changed the rules that matter most to exporters: a new 50-tonne exemption, a delayed February 2027 start for buying certificates, and lighter quarterly obligations. Here is exactly what applies to you now — and what to do before 2027.
What is CBAM and what changed for 2026?
CBAM is the EU's carbon tariff on imported carbon-intensive goods. It ensures imported products carry the same carbon cost as EU-made goods under the EU Emissions Trading System (ETS), closing the "carbon leakage" gap. After a transitional reporting phase from October 2023 to December 2025, the mechanism entered its definitive (financial) phase on 1 January 2026.
Crucially, the CBAM Omnibus Regulation — adopted in 2025 with implementing acts published on 17 December 2025 — introduced binding simplifications right before the definitive phase began. If you prepared against the original 2023 rules, several of your assumptions have now changed. The three that matter most are covered below.
Change 1: The new 50-tonne de minimis exemption
The single biggest change is a new mass-based exemption. Importers bringing 50 tonnes or less of CBAM-covered goods into the EU per calendar year (cumulative net mass) are now fully exempt from CBAM obligations.
According to the European Commission, this threshold removes roughly 90% of importers from the scheme while still capturing about 99% of the embedded emissions — because the exempted importers are overwhelmingly small-volume traders. Two exclusions apply: hydrogen and electricity do not benefit from the exemption.
Change 2: Certificate purchases postponed to February 2027
Under the original rules, declarants would have started buying CBAM certificates on 1 January 2026. The Omnibus postponed the start of certificate sales to 1 February 2027. In practice:
- Embedded-emissions obligations still apply to 2026 imports.
- The actual purchase and surrender of certificates happens in 2027, retroactively covering 2026.
- This gives exporters and importers a full extra year of cash-flow relief — but not a reprieve from data collection.
A second relief: the requirement to hold certificates on the registry account at the end of each quarter was reduced from 80% to 50% of the embedded emissions in goods imported since the start of the year.
Change 3: How much will CBAM actually cost?
A CBAM certificate's price is tied to the weekly average auction price of EU ETS allowances, expressed in euros per tonne of CO₂. Because it tracks the live carbon market, the cost moves with the EU ETS price, which has recently traded broadly in the €70–€90 per tonne CO₂ range (illustrative — always check the current ETS price).
| Product line | Annual EU export volume | Assumed embedded emissions | Illustrative CBAM cost/yr (@ €80/t CO₂) |
|---|---|---|---|
| Carbon steel (hot-rolled) | 2,000 t | ~1.9 t CO₂ / t steel | ≈ €304,000 |
| Primary aluminium | 500 t | ~8.0 t CO₂ / t (world avg) | ≈ €320,000 |
| Portland cement | 5,000 t | ~0.85 t CO₂ / t | ≈ €340,000 |
| Nitrogen fertiliser | 1,000 t | ~2.5 t CO₂ / t | ≈ €200,000 |
The single most important lever on this number is using verified actual emissions instead of the EU's default values. Default values are deliberately conservative (high). Exporters that can prove lower actual emissions with proper monitoring typically pay significantly less. Our free open-source CBAM calculator and default-value templates on GitHub let you model both scenarios.
Watch: how CBAM works in 90 seconds
▶ "EU CBAM 2026 Explained" — via CleanCarbon.ai
Who must comply — covered sectors at a glance
| Sector | In CBAM scope? | Benefits from 50-t exemption? |
|---|---|---|
| Iron & steel | ✅ Yes | ✅ Yes |
| Aluminium | ✅ Yes | ✅ Yes |
| Cement | ✅ Yes | ✅ Yes |
| Fertilisers | ✅ Yes | ✅ Yes |
| Hydrogen | ✅ Yes | ❌ No (excluded) |
| Electricity | ✅ Yes | ❌ No (excluded) |
| Textiles, leather, food | ❌ Not yet | — |
If you export cement, steel or aluminium into the EU, CBAM applies directly. Exporters in textiles and other sectors are not yet in CBAM scope but face parallel EU pressure through CSRD and supplier data requests — see our pillar guide on EU carbon compliance for textile exporters.
Your step-by-step CBAM compliance timeline for 2026
Because payment is deferred to 2027, 2026 is your window to get the data right. A verified emissions figure prepared calmly this year is far cheaper than a default-value liability calculated in a rush next year.
- Q3 2026 — Confirm scope & volume. Total your annual EU-bound tonnage of covered goods. Under 50 t? Document it and monitor. Over 50 t? Proceed.
- Q3 2026 — Map installations & emissions sources. Identify every production route and its direct + indirect emissions.
- Q4 2026 — Collect primary data. Replace EU default values with monitored actual emissions using the GHG/CBAM methodology. This is where our CBAM Embedded-Emissions Verification service does the heavy lifting.
- Q4 2026 — Prepare the importer handover pack. Your EU importer (the "authorised CBAM declarant") needs your verified data to file — so give it to them in the correct format.
- Early 2027 — Support the annual CBAM declaration. The first declaration covering 2026 imports is filed in 2027; certificate purchases open 1 February 2027.
Not sure where your Scope 1, 2 and 3 emissions sit? Start with the fundamentals in our guide to carbon accounting Scope 1, 2 & 3 demystified.
Turn CBAM from a cost into a competitive edge
We convert EU default values into verified actual emissions, prepare importer-ready handover packs, and build your quarterly monitoring — backed by €2.3M PI insurance and a TÜV-certified ISO 14001 auditor.
📅 Book a Free 30-Minute CBAM Strategy CallFrequently asked questions
When did the CBAM definitive period start?
The definitive period began on 1 January 2026, following the transitional reporting phase (October 2023–December 2025). From 2026, embedded emissions carry a financial obligation — but certificate purchases only begin in February 2027.
What is the CBAM 50-tonne de minimis threshold?
Importers bringing 50 tonnes or less of CBAM-covered goods into the EU per calendar year (cumulative net mass) are exempt. Hydrogen and electricity are excluded. The threshold exempts ~90% of importers while still covering ~99% of embedded emissions.
When do we have to buy CBAM certificates?
Certificate sales were postponed from 1 January 2026 to 1 February 2027. Declarants purchase certificates in 2027 to cover 2026 imports, applied retroactively.
How much does a CBAM certificate cost?
The price tracks the weekly average EU ETS auction price in euros per tonne of CO₂. It fluctuates with the carbon market and has recently traded broadly in the €70–€90/t CO₂ range.
Do textiles or leather fall under CBAM?
Not currently. CBAM covers iron & steel, aluminium, cement, fertilisers, hydrogen and electricity. Textile and leather exporters instead face CSRD and buyer-driven ESG data requirements.
Sources & further reading
- European Commission — Carbon Border Adjustment Mechanism (official): taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en
- International Carbon Action Partnership — "EU adopts simplifications of CBAM rules ahead of the compliance phase starting in 2026": icapcarbonaction.com
- Reed Smith — "What you need to know as CBAM simplification comes into effect": reedsmith.com
- Herbert Smith Freehills Kramer — "Operationalisation and simplification of the EU CBAM": hsfkramer.com
This article is general guidance, not legal or tax advice. CBAM rules and the EU ETS price change frequently — verify current figures against the official European Commission source before making decisions.