European Union: the Carbon Border Adjustment Mechanism (CBAM) has entered its definitive phase

After a purely reporting-based transitional period between October 2023 and the end of 2025, the European Union's Carbon Border Adjustment Mechanism (CBAM) entered, on 1 January 2026, its definitive, financial regime. The sectors covered remain cement, iron and steel, aluminium, fertilisers, hydrogen and electricity.

Any importer of CBAM goods exceeding the de minimis threshold of 50 tonnes a year (with no threshold for hydrogen and electricity) must become an authorised CBAM declarant with the competent authority of their Member State, declare each year the greenhouse gas emissions embedded in the production of the imported goods, then buy and surrender a number of certificates corresponding to those emissions.

The price of the certificate is indexed to the price of allowances on the European carbon market (EU ETS), calculated as a quarterly average for 2026 and then as a weekly average from 2027. An importer may deduct the amount already paid if a carbon price was paid during production abroad, subject to supporting evidence. The central sales platform for certificates will, however, only open in February 2027, and the first annual declaration, with surrender of the corresponding certificates, is not due until 30 September 2027, to cover imports from 2026.

Chinese steel, aluminium or fertiliser-based products whose tariff code appears in the annexes to the CBAM Regulation fall within scope, whether raw or already processed into parts or structures.