CBAM 2026: the year it stopped being paperwork
CBAM 2026 is the first year of the definitive regime. The transitional period — quarterly reports, no money — ended on 31 December 2025. Emissions embedded in goods imported from 1 January 2026 carry a real price, payable in certificates and surrendered in 2027.
What CBAM 2026 changed in January
Three things. Reporting moved from quarterly to annual. Emissions acquired a price — the first published quarterly certificate price was EUR 75.36 per tonne of CO2. And a legally binding de minimis exemption arrived: importers below 50 tonnes of CBAM goods a year are out of scope entirely.
Why the exemption cuts both ways
The 50-tonne floor removes thousands of small importers from the system. For a producer it means fragmentation: the same factory can be exempt through one customer and fully in scope through another. You cannot predict which buyer will ask, so the only workable position is to have the data ready before any of them do.
The dates to hold on to
- 1 January 2026 — definitive period opens.
- 1 February 2027 — certificate sales open on the central platform.
- 30 September 2027 — annual declaration and first surrender for 2026 imports.
What CBAM 2026 means for a supplier outside the EU
Nothing legally. No obligation from Brussels lands on a company in Albania, Serbia or Türkiye. The pressure arrives commercially instead: your EU customer now has a cost attached to buying from you, and the size of that cost depends on data only you can supply.
If you supply it, the declarant uses your actual figures. If you do not, they apply default values set deliberately high, and the difference lands on your price. That is the whole mechanism, and it is why the request tends to arrive from procurement rather than from anyone's sustainability team.
Which goods CBAM 2026 covers
The definitive period covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, identified by CN code rather than by industry description. Coverage follows the code on the customs declaration, so a company can be in scope for one product line and out of scope for another.
The Commission has signalled extension to downstream products and further sectors. Assuming today's scope is permanent is not a plan.
What to do during 2026
Record now what you will be asked for in 2027. Monthly energy consumption per facility, fuel purchases, production volumes by route, and the source documents behind each. The reporting year is already running, and a month that was never recorded cannot be reconstructed once it has passed.
Companies that start collecting when the first request arrives spend the following quarter reconstructing a year they no longer have records for.