CBAM in 2026: What EU Importers of Steel, Aluminium and Fertilisers Need to Know

Since 1 January 2026, the EU Carbon Border Adjustment Mechanism — CBAM — has operated under its definitive regime. Importers of covered goods must consider not only purchase prices, freight and customs duties, but also obligations associated with emissions generated during production. 

For Ukrainian businesses, two situations must be distinguished: supplying goods to the EU market and delivering goods to Ukraine in transit through EU territory. A route through Poland or Romania does not, by itself, determine whether CBAM obligations arise.

What is CBAM, and who is responsible?

CBAM — Carbon Border Adjustment Mechanism — accounts for emissions embedded in certain goods imported into the EU. It is neither a fixed percentage of the invoice value nor a freight charge.

Unless an applicable exemption applies, imports must be handled through an authorised CBAM declarant. This is the importer or an indirect customs representative under the arrangements provided by the rules. An EORI number alone does not replace CBAM authorisation. 

The manufacturer supplies the necessary production information, while the logistics partner coordinates transport and documentation within the agreed scope of services. When arranging customs brokerage services, identify who will handle CBAM separately: ordinary customs representation does not automatically include carbon reporting support.

Which goods are covered? Sector-specific considerations

Start with the CN code under the EU Combined Nomenclature. Commercial descriptions such as “metal”, “aluminium components” or “fertilisers” are not sufficiently precise. The examples below do not replace checking the full commodity code and applicable exclusions.

Steel: finished products as well as raw materials

Coverage includes certain rolled steel products and fasteners under heading 7318. For screws or nuts made from purchased steel rods, calculations also account for the embedded emissions of those rods, not just subsequent processing.

The practical lesson for procurement teams is to ask more than whether a material quality certificate is available. Establish who manufactured the input material and who will prepare the CBAM data, especially when buying from a trading company rather than a mill.

Aluminium: profiles, sheets and tubes

Examples include heading 7604 for bars, rods and profiles, 7606 for plates, sheets and strip exceeding 0.2 mm in thickness, and 7608 for tubes and pipes. For aluminium goods listed in Annex II, the definitive regime accounts for direct emissions, excluding indirect electricity emissions.

A general environmental document or a marketing claim about “green aluminium” is therefore insufficient to establish whether the data is suitable. Ask the supplier to identify the product, installation and methodology to which its figures relate.

Fertilisers: composition and nitrogen content matter

Relevant categories include urea, ammonium nitrate and certain mixed fertilisers. Both direct and indirect emissions are considered for covered fertilisers. Nitrogen content also matters in calculations under the CBAM methodology. 

For example, an enquiry for UAN-32 should request the specification, confirmed composition, manufacturer and CN code from the outset. Figures for another fertiliser should not be reused simply because both products are liquids or travel in the same type of vehicle.

CBAM data preparation and international fertiliser transport should be coordinated, but not confused: transport safety and carbon accounting address different requirements.

How does the 50-tonne threshold work?

The mass-based exemption applies where relevant imports do not exceed 50 tonnes net per importer per calendar year. Covered goods are aggregated across shipments and categories. Exceeding the threshold brings the relevant imports for the whole year into scope, including earlier consignments. Hydrogen and electricity are excluded from this exemption. 

For illustration, 30 tonnes of covered steel and 25 tonnes of covered aluminium total 55 tonnes. Reviewing each order separately would conceal the threshold being exceeded. A shared annual register should therefore be available to procurement, accounting and the person responsible for imports.

Key deadlines for 2026 imports

Deferring certificate purchases until 2027 does not remove the obligations associated with 2026 shipments. 

Financial plans should distinguish the import date, estimated liability and future payment. Otherwise, costs may appear in the budget after the goods have already been sold to the customer.

What information should be collected before dispatch?

A practical package to agree with the CBAM declarant includes:

1. Product description, CN code, specification and net mass.
2. Country of origin, manufacturer and production installation.
3. The chosen approach: actual emissions or permitted default values.
4. Where actual data is used, the necessary production figures, relevant precursor information and verification documentation.
5. Evidence of a carbon price paid where a corresponding reduction will be claimed.
6. The supplier’s responsible contact and deadlines for resolving discrepancies.

This is an organisational checklist, not a universal declaration form. Agree which fields are needed for the specific goods before submitting documents.

Actual figures require the verification prescribed under CBAM. Default values should come from current definitive-period materials, not outdated transitional reporting tables. 

How should businesses assess the cost impact?

Multiplying cargo weight by the certificate price will not produce a valid calculation: a tonne of goods is not the same as a tonne of emissions.

The calculation depends on embedded emissions, applicable adjustments — including the EU ETS free allocation adjustment — and any permitted recognition of a carbon price already paid. Certificate prices for 2026 imports are determined quarterly. 

Commercial calculations should show the goods, delivery, customs duties, estimated CBAM cost and data preparation separately. This allows suppliers to be compared on total cost rather than invoice price alone.

Transit through the EU to Ukraine is not the same as an EU import

External transit without release for free circulation in the EU does not, by itself, create the ordinary CBAM import obligation. If the goods are first released for free circulation, the assessment changes.

This is why customs clearance arrangements in EU countries should be agreed before dispatch. The transport request should clearly identify the final consignee and intended procedure, not merely the port or border crossing.

What to do before the next shipment

Check the product classification, annual import volume, responsible CBAM declarant and availability of manufacturer data. Then agree the budget and customs procedure.

This makes CBAM part of preparing international freight transport. Material traceability is particularly important for steel, the correct emissions accounting boundaries for aluminium, and composition and production figures for fertilisers. Resolving these questions early reduces uncertainty around both the cost and execution of the shipment.