Am I subject to CBAM?

Since 1 January 2026 the EU Carbon Border Adjustment Mechanism (CBAM) has been in its definitive period. Whether your company has obligations depends on three questions: which goods you import, where they originate and how much you import per year. This page takes you through all three.

At a glance

Only goods listed in Annex I of the CBAM Regulation are covered: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. The CN code decides, not the product name.
Goods originating in Iceland, Liechtenstein, Norway and Switzerland are excluded.
Up to 50 t net mass per calendar year, importers are exempt; above it, the obligations apply to all imports of the year.
There is no threshold for electricity and hydrogen: authorisation is needed from the first import.
If you are subject to CBAM, the first annual declaration for 2026 is due by 30 September 2027.

Question 1: Are your goods listed in Annex I?

CBAM does not cover industries but CN codes. What matters is the CN code – the first eight digits of the commodity code in your customs declaration – not the product name or the intended use. Annex I of Regulation (EU) 2023/956 lists the codes concerned in six sectors.

They include many finished products, such as screws, tubes and steel structures from chapter 73 or aluminium profiles and foil. Other goods are expressly excluded, for example steel or aluminium scrap. The pages on the individual sectors show exactly which codes are covered.

Question 2: Where do the goods originate?

CBAM applies to goods originating outside the EU. Under Annex III of the Regulation, goods originating in Iceland, Liechtenstein, Norway and Switzerland as well as Büsingen, Heligoland, Livigno, Ceuta and Melilla are excluded. The country of origin of the goods counts, not the country the shipment comes from.

The obligations fall on the importer – the person in whose name the goods are declared for release for free circulation. If you buy steel from a dealer in the EU who imported it, you are not the importer.

Question 3: Do you import more than 50 t a year?

Since 2026 there is a mass threshold of 50 t net mass per importer and calendar year, added up across iron and steel, aluminium, cement and fertilisers (Art. 2a). If you stay below it, you are exempt from CBAM obligations for that year. If you exceed it, the obligations apply to all CBAM imports of the year – from the first tonne.

Anyone expecting to exceed the threshold must apply for authorised CBAM declarant status in advance (Art. 5(1b)). The competent authority (in Germany: DEHSt) has 120 days to decide (Art. 4 Implementing Regulation (EU) 2025/486); if it requests more information, the period is extended. There is no threshold for electricity and hydrogen: authorisation is required from the first import.

Special cases: customs agency and importers outside the EU

If a customs agency declares CBAM goods as an indirect customs representative in its own name, it must itself be an authorised CBAM declarant – regardless of the quantity. For importers established in the EU it can decline the CBAM obligations; they then remain with the importer.

Importers not established in an EU Member State – for example a supplier delivering duty paid (DDP) – cannot become CBAM declarants themselves. Then the indirect customs representative must be authorised, even if the importer stays below the threshold (Art. 5(2)).

What follows if you are subject to CBAM?

Anyone above the threshold or importing electricity or hydrogen has these obligations in the definitive period:

Authorised CBAM declarant status from the competent authority (in Germany: DEHSt) – before exceeding the threshold
Obtain emission data from producers; without verified data, official default values with a mark-up apply
CBAM annual declaration for 2026 by 30 September 2027 in the CBAM registry
Buy certificates (from 1 February 2027) and surrender them by 30 September 2027; from 2027 a holding obligation applies at the end of each quarter

How CBAMfix helps

Threshold Watch (€29.00 a month incl. VAT) reads your import documents with AI, checks every CN code against Annex I and counts the net mass per calendar year. From the course so far, CBAMfix projects when the threshold is likely to be crossed and warns you before the time for the authorisation application gets tight.

Frequently asked questions

Am I subject to CBAM if I only import a little steel?

Not as long as you import a total of no more than 50 t of CBAM goods from iron and steel, aluminium, cement and fertilisers in the calendar year. Keep count anyway: if you exceed the threshold, the obligations apply to the whole year.

Does CBAM apply to goods from Switzerland or Norway?

No. Goods originating in Iceland, Liechtenstein, Norway and Switzerland are excluded under Annex III of the CBAM Regulation. The origin of the goods counts, not where the supplier is based.

I buy from a dealer within the EU – does CBAM affect me?

Usually not. The obligations lie with the importer, i.e. the person in whose name the goods were declared to customs in the EU. However, if your dealer ships directly from a third country and you are named as importer in the customs declaration, you are the importer.

How do I know whether my goods are covered by CBAM?

From the CN code in the customs declaration or customs duty notice. With the free CBAMfix CN code check you see immediately whether the code is listed in Annex I.

What does CBAM cost?

One certificate must be surrendered per tonne of embedded emissions, minus the free allocation adjustment. For imports in 2026 the quarterly price of the quarter of import applies, most recently €82.32. The cost calculator on the certificates page works this out for your CN code and country of origin.

Stay on top of the 50-tonne threshold

CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.

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