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CBAM · EU Carbon Border Adjustment Mechanism

Transition-period quarterly reporting ended in Dec 2025. From 1 Jan 2026, the definitive regime applies a 50-tonne annual threshold, authorised-declarant status, annual declarations and certificate surrender.

Industries: Steel / Aluminium / Cement / Fertilizer / H₂ / Power

Key dates
  • 2023.05.17CBAM enters into force
  • 2023.10.01Transition period begins · quarterly reports start (data only, no payment)
  • 2025.12.31Transition period ends · last data-only quarterly report
  • 2026.01.01Definitive period begins · 50-tonne threshold and authorised-declarant regime apply
  • 2027.09.30First annual declaration and certificate surrender deadline (covering 2026 imports)

AMT: CBAM Reporting · PCF · Carbon Asset · DPP

Overview

Full name
EU Carbon Border Adjustment Mechanism (CBAM) · Regulation (EU) 2023/956
Authority
European Commission + member-state customs
Effective
Transition 2023.10.01–2025.12.31 / Definitive from 2026.01.01
Scope
Steel / cement / fertilizer / aluminium / electricity / hydrogen / selected downstream goods
Mechanism
Authorised CBAM declarant + annual embedded-emissions declaration + purchase and surrender of CBAM certificates priced against EU ETS

CBAM is the EU mechanism for preventing carbon leakage and applying a corresponding carbon cost to imports. Transition-period quarterly reporting ended in 2025. From 2026, a cumulative annual exemption of 50 tonnes per importer applies to cement, iron and steel, aluminium and fertilisers; electricity and hydrogen are excluded from that mass-based exemption. Importers above the threshold need authorised CBAM declarant status, must file annual embedded-emissions declarations and surrender certificates. Definitive-period rules allow EU default values where prescribed, or actual emissions calculated under EU methods and verified, so exporters should still prepare auditable production and emissions data.

Timeline

From entry into force to key milestones — every compliance checkpoint.

  1. 2023.05.17
    CBAM enters into force
  2. 2023.10.01
    Transition period begins · quarterly reports start (data only, no payment)
  3. 2025.12.31
    Transition period ends · last data-only quarterly report
  4. 2026.01.01
    Definitive period begins · 50-tonne threshold and authorised-declarant regime apply
  5. 2027.09.30
    First annual declaration and certificate surrender deadline (covering 2026 imports)
  6. 2034.01.01
    Free allowances fully phased out (10-year ramp)

Who must comply

Self-check across industry, scale and export scope.

Industry

Steel / cement / fertilizer / aluminium / electricity / hydrogen, plus selected downstream goods such as bolts and screws.

Company size

Regardless of size — any exporter shipping covered goods to the EU is affected.

Key test

Do you export to the EU, and is the product on the CBAM list (by CN customs code)?

Industry solutions: Overseas-Compliance Solution

Key requirements

Meet these core requirements to comply and access the market.

1

Authorisation and threshold: covered goods above the cumulative 50-tonne annual threshold per importer generally require an authorised CBAM declarant.

2

Emissions values: use EU default values where allowed, or actual values calculated under the EU methodology.

3

Third-party verification: actual embedded-emissions data must be verified under the definitive-period rules.

4

CBAM certificates: importers buy certificates per tonne of embedded emissions, priced against the weekly average EU ETS price.

5

Annual declaration: the first filing covers 2026 imports and is due on 30 Sep 2027; later filings follow the definitive annual cycle.

6

Penalties: failure to report, mis-reporting or under-reporting incurs fines per tonne of embedded emissions.

FAQ

What’s the difference between the transition and definitive periods?

The transition period (Oct 2023–Dec 2025) used payment-free quarterly data reports. The definitive period from Jan 2026 uses authorised declarants, annual declarations and certificate surrender, with a 50-tonne annual threshold.

The obligation sits with the importer — why must exporters prepare?

Embedded-emissions data comes from the exporter’s production. EU importers need the exporter’s computed (and ultimately verified) product carbon footprint; otherwise only higher default values apply, inflating the tariff.

Can default values be used in the definitive period?

EU default values may be used where the rules permit, or verified actual values may be submitted under the EU methodology. Companies should compare the two routes and avoid promising a fixed saving before the applicable rules and data are confirmed.

Which products does CBAM cover?

Steel, cement, fertilizer, aluminium, electricity, hydrogen and selected downstream goods such as bolts and screws — determined by CN customs codes.

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