Practical guide

CBAM on EU imports: a practical guide for businesses

If you buy steel, aluminium, cement or other covered goods outside the EU, CBAM can become part of the cost and paperwork of the import when no exemption applies, such as the annual 50-tonne exemption for some sectors. This guide explains what to check before closing an order in China, without alarmism and without shortcuts.

Updated: 15 October 2026

Written by the EC HolaHome team, based on the official European Commission and Spanish Ministry (MITECO) sources linked in each section.

In short

CBAM is not a general duty or a percentage of the invoice: it applies to certain goods by CN code, is calculated on embedded emissions and, when no exemption applies, requires authorisation and data from 2026 and, from 2027, an annual declaration and surrender of certificates. The volume exemption of up to 50 t of net mass a year exists only for four sectors: iron and steel, aluminium, cement and fertilisers.

1. What CBAM is and what it is not

The Carbon Border Adjustment Mechanism (CBAM) puts a price on the emissions embedded in certain goods imported from non-EU countries into the EU customs territory. It complements the EU Emissions Trading System (EU ETS).

It is not a general percentage of the invoice or a universal duty: it only affects covered goods and depends on their emissions.
China is not among the origins with a geographical exemption under Annex III; even so, check whether the volume exemption or another applicable exemption applies. The origin of the goods matters, not just the invoicing country.
Buying from a distributor in Germany goods already released for free circulation in the EU does not create a new CBAM import: movement within the EU is not one. The cost borne by the original importer may be passed on in the price.
A seller or port of call in the EU does not take Chinese goods out of scope if they are still in transit or in storage: check their customs status and who the responsible importer will be.

European Commission: CBAM definitive regime

2. Which goods are covered

Scope is set by the Combined Nomenclature (CN) code listed in the current Annex I of the Regulation, not by trade name or main material. There are six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.

Indicative examples by sector: not every code in each family is covered
Sector	Indicative examples	What to check
Iron and steel	Sections, tubes, sheets, certain screws and fasteners	Exact CN code against Annex I
Aluminium	Profiles, bars, sheets, certain structures	Whether the code of the complete product is listed
Cement	Clinker and cements	Code and installation of origin
Fertilisers	Certain nitrogen fertilisers	Code and composition
Electricity	Imported electricity	Specific regime, no 50 t threshold
Hydrogen	Hydrogen	No 50 t threshold

A piece of furniture or an appliance containing metal parts is not automatically covered: the CN code of the complete product as declared is what counts. Validate the classification with your customs representative and check TARIC.

The Commission has tabled a proposal, COM(2025) 989, to extend the mechanism to certain downstream products. It is a proposal: do not treat it as a current obligation, but keep it in mind if you buy steel or aluminium components.

3. The 50-tonne threshold: how it is counted

For iron and steel, aluminium, cement and fertilisers there is an exemption if the importer does not exceed 50 tonnes of cumulative net mass of CBAM goods in a calendar year. Electricity and hydrogen have no such exemption.

All of the importer's covered goods are added up: across codes, suppliers, shipments and Member States of entry. It is not counted per invoice, container or supplier.
Exactly 50 tonnes is exempt; the exemption is lost once that is exceeded.
If it is exceeded during the year, obligations apply to all covered goods imported that year, including those imported before it was exceeded. It is not an allowance on the first 50 tonnes.
Splitting orders or switching between LCL and FCL does not avoid the count. If you consolidate goods from several factories, keep traceability of each origin and installation.
Some geographical exemptions (Norway, Iceland, Liechtenstein and Switzerland, under Annex III) depend on origin, not on the seller being in the EU.
Being exempt from CBAM does not exempt you from other customs obligations.

Illustrative example: assuming Annex I codes and a non-exempt origin
Import during the year	Net mass	Result
Steel sections (several shipments)	38 t	Counts towards the threshold
Aluminium profiles	15 t	Counts towards the threshold
Annual total	53 t	Exceeds 50 t: obligations on all 53 t, not only 3 t

4. Timeline to keep in mind

Goods imported from 2026 already count towards the first declaration. Do not wait until 2027 to organise registration and data.

CBAM milestones
Date	What happens
1 Oct 2023 – 31 Dec 2025	Transitional phase: emissions reporting only
1 Jan 2026	Definitive regime: 2026 imports create obligations if the 50 t threshold is exceeded; electricity and hydrogen have no volume exemption
From February 2027	Sale of CBAM certificates for 2026
30 Sep 2027	First annual declaration and surrender of 2026 certificates
Every following 30 Sep	Declaration and surrender for the previous year's imports

Authorisation as a CBAM declarant is requested from the competent authority of the country of establishment; check the status of your application before importing volumes that could exceed the threshold.

5. Who is responsible

The obligation lies with the importer or the authorised CBAM declarant; in some cases with the indirect customs representative when acting as such. You will need an EORI number and access to the CBAM Registry through the authority of your country of establishment.

In Spain, MITECO (Spanish Climate Change Office) is the CBAM authority, and the Tax Agency (AEAT) handles customs clearance.
A third party can help you or submit the declaration on your behalf, but that does not transfer the declarant's responsibility.
Do not assume that a sourcing agent or freight forwarder takes on the declarant role just because a contract mentions it.
EC HolaHome can coordinate data collection, documentation and logistics with the supplier. Verification is carried out by an accredited verifier, and the obligations lie with whoever legally acts as the authorised declarant.

Related on this site:Import management

6. Data to request from the factory before buying

Actual emissions data must be calculated with the CBAM methodology and verified; the official template makes it easier to exchange information with the factory. A “green factory” claim, an ISO certificate or a generic carbon footprint is not enough.

Actual values must be verified by an accredited verifier. Without actual data, the official default values applicable to the product, origin and period are used. Do not assign zero emissions for lack of information or use unsupported figures. Use the values updated by Regulation (EU) 2026/1740, which corrected them in July 2026.

Keep traceability between order, batch, customs declaration, EORI and weights: you will need it for the annual declaration.

Information to request before the order

Product and proposed CN code, to validate with your customs representative.
Net mass per reference and per shipment.
Country of origin, factory and specific installation, and production period.
Production route and precursors used.
Direct and indirect emissions, where applicable to the product, calculated with the CBAM methodology.
Who provides accredited verification of actual values, by when and at what cost.
Evidence of any carbon price effectively paid at origin.

European Commission: legislation, default values and guidance

7. How to estimate the cost

The starting point is mass times emission intensity: tonnes × tCO2e per tonne = embedded emissions. That figure is not simply the number of certificates to pay for.

An adjustment is applied for EU ETS free allocation, based on the product benchmark and the year.
Any carbon price effectively paid at origin is deducted, with evidence and net of rebates or compensation.
The certificate price in €/tCO2e is applied to the resulting obligation, plus data management and verification.
In 2026 the price is the quarterly EU ETS average for the quarter of import; from 2027 prices will be weekly. Check the official publication rather than using a fixed price.
Do not apply rules such as “2.5% of the invoice” or a universal percentage of emissions.

Purely teaching example: not a CBAM bill
Step	Value
Imported mass	60 t
Hypothetical intensity	2 tCO2e/t
Embedded emissions (before adjustments)	120 tCO2e

These 120 tCO2e are not 120 certificates to buy: the adjustments above are still missing. A usable estimate needs classification, quantities, verified actual emissions or applicable official default values, adjustments and the relevant price; an indicative calculation does not replace the declaration. This site's general calculator estimates duties and VAT, but it does not settle CBAM.

European Commission: price of CBAM certificates

8. How it affects the buying decision

CBAM adds a variable worth knowing before the order, not when the goods arrive.

Request emissions information before confirming the order and compare suppliers on total cost, not catalogue price.
Using default values is a legal option where applicable and does not automatically mean ruling out the factory. Compare the result with verified actual data, without assuming a saving.
Mistakes on responsibility, registration or deadlines can lead to holds or penalties.
CBAM does not replace duties, VAT or any anti-dumping duties: each is calculated separately.

9. Practical steps

A sensible work order for a company buying materials or metal products in China.

Classify each product by CN code with your customs representative and check Annex I.
If you import iron and steel, aluminium, cement or fertilisers, estimate the annual net mass across all suppliers and shipments; electricity and hydrogen have no mass exemption.
If no exemption applies, apply for authorisation and Registry access in advance.
Include emissions data and verification in your request for quotation.
Compare offers with actual data against default values.
Set out in writing who prepares data, who verifies and who declares.
Keep traceability by order and batch throughout the year.

Before buying

CBAM checklist

Six checks before confirming an order of covered goods.

The CN code is validated and you know whether it is listed in the current Annex I.
You know whether your sector has a mass exemption and, if so, your cumulative annual net mass against 50 t.
You know who the CBAM declarant will be and that they have Registry access.
The factory has confirmed which emissions data and verification it can provide.
The cost estimate separates emissions, adjustments and certificate price.
Order-batch-customs declaration traceability is organised.

FAQ

Common questions about CBAM

If I buy steel from a company in another EU country, do I have CBAM obligations?: If the goods were already released for free circulation in the EU, the intra-EU purchase is not a new CBAM import. The cost may be included in the price.
My product contains metal. Is it covered?: Not automatically. The CN code of the complete product against Annex I decides.
What if I import exactly 50 tonnes? And 53?: The mass exemption only exists for iron and steel, aluminium, cement and fertilisers; it does not apply to electricity or hydrogen. In those sectors exactly 50 t is exempt; once you exceed the threshold, obligations apply to all covered goods imported that year.
If I import in 2026, when do I pay?: 2026 certificates go on sale from February 2027 and are surrendered with the first declaration, by 30 September 2027.
Can the factory simply send me its emissions data?: To use actual values they must follow the CBAM methodology and be verified by an accredited verifier. Otherwise official default values apply.
Can I delegate the declaration?: You can delegate submission to a third party, but responsibility remains with the declarant.
Does consolidating shipments from several factories change anything?: The threshold is counted per importer and year, not per shipment. Consolidation does not reduce the count; keep data by origin and installation.
Can I calculate CBAM with your calculator?: No. The calculator gives an indicative estimate of duties and VAT; CBAM depends on emissions, adjustments and the official certificate price.

Note

Informational guide; confirm the classification and obligations of each operation with your customs representative and the competent authority. Official sources consulted on 15 October 2026.

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