CBAM: first annual declaration and surrender of certificates for 2026 imports of steel, aluminium, cement, fertilisers
Date note: Definitive period started 2026-01-01; importers above 50 tonnes/year had to apply for authorised CBAM declarant status by 2026-03-31. Declaration deadline per the 2025 CBAM simplification regulation – confirm with your national CBAM authority
What changes
Since 1 January 2026 importers of more than 50 tonnes per year of CBAM goods (iron and steel, aluminium, cement, fertilisers; plus hydrogen and electricity without threshold) must be authorised CBAM declarants and buy CBAM certificates covering the embedded emissions. The first annual declaration and certificate surrender for 2026 imports is due in 2027. Importers under 50 tonnes are exempt but must monitor the threshold.
Who is affected
Any business importing the listed goods from outside the EU, including small manufacturers, construction firms and traders buying steel or aluminium products directly from non-EU suppliers.
Sizes: micro, small, medium, large · Sectors: Manufacturing, Construction, Hardware / electronics, Agriculture / food, Energy · Applies if: We import goods into the EU
What to do
Track cumulative annual imports of CBAM goods by weight to know if you cross 50 tonnes. If you do, make sure your authorised declarant status is granted, collect actual emissions data from suppliers (or use default values), buy certificates during 2027 and file the declaration in the CBAM registry by the deadline.
Penalty
Penalty per certificate not surrendered, plus loss of authorisation for repeated breaches
Sources
- European Commission – CBAM definitive regime (taxation-customs.ec.europa.eu)
- European Commission Access2Markets – Start of the definitive period of the CBAM (trade.ec.europa.eu)
- Customs Support – CBAM: the 2026 changes (www.customssupport.com)
Last verified 7 September 2026. Informational only, not legal advice.