EU Regulatory Regime · High
CBAM — Carbon Border Adjustment Mechanism — importer obligations + worked example
Status
Status: Active — definitive period from 1 January 2026. Key dates: 2026-01-01: definitive period began. 2026-05-31: first annual declaration deadline (covering 2025 transitional period).
What you must do as the importer
Register as authorised CBAM declarant via your national competent authority. From 1 January 2026, purchase CBAM certificates priced against weekly EU ETS settlement to cover embedded emissions of imported goods. Quarterly reporting was transitional (2023-2025); annual declaration now applies.
What goods are covered
- 2523 — Cement
- 2716 — Electricity
- 280410 — Hydrogen
- 281410 — Anhydrous ammonia
- 281420 — Ammonia in solution
- 31 — Fertilisers
- 72 — Iron and steel
- 7301 — Articles of iron/steel — sheet piling
Worked example: a typical shipment that triggers
A €50,000 shipment of machinery (HS 252300) from CN into the EU triggers CBAM — Carbon Border Adjustment Mechanism. The customs duty + VAT are calculated as normal — but on top of that, the importer must satisfy the obligations above before the goods can be placed on the EU market.
Non-compliance is not a duty event — it is a market-access event
A common misunderstanding: importers focus on duty + VAT and treat compliance as a tickbox. EU customs increasingly hold goods at the border for missing documentation (DDS for EUDR, CBAM declarant status for steel/aluminium, EU Responsible Person for cosmetics). Holds become storage charges; storage charges become forced re-export. Validate before booking the freight.
Related OrcaTrade resources
See whether this regime applies to your specific shipment
Six questions, all four calculators (sourcing, routing, customs, warehouse), full landed cost — with this regime flagged on your specific HS code if applicable.
Build my plan with this regime checked →