Overview of CBAM Obligations

Last update 17/04/2026

This page clarifies whether you are affected by CBAM obligations and provides an overview of the obligations in the transitional period (October 2023 to the end of 2025) and in the definitive regime from 01/01/2026 onwards.

Do CBAM Obligations apply to me?

Whether and to what extent CBAM obligations apply to you basically depends on whether you import CBAM goods originating in a third country into the EU and to what extent exemptions apply to you.

Quick check in 5 steps

What are CBAM goods?

CBAM goods are goods from the electricity, cement, iron and steel, fertiliser, hydrogen and aluminium sectors listed in Annex I of Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a Carbon Border Adjustment Mechanism (hereinafter referred to as the CBAM Regulation). In addition to basic materials, certain downstream products (for example screws) are also affected by CBAM.
Sector-specific information from the European Commission
Sector-specific information from the European Commission
Do these goods originate in a third country?

A third country means a country or territory outside the customs territory of the EU (Article 3(7) CBAM Regulation).

Please note that the non-preferential rules of origin according to Article 59 of Regulation (EU) 952/2013 (Union Customs Code) apply in CBAM.

The non-preferential rules of origin according to Article 59 of the Union Customs Code determine which country is considered the country of origin of a product if the goods have been manufactured or processed in several countries. The country of origin determines which standard values can be used for the goods (parts) and which CO2 price can potentially be taken into account.
What does ‘import’ mean in CBAM?

In CBAM, import is defined as the release for free circulation in accordance with Article 201 of the Union Customs Code (Article 3(4) CBAM Regulation).

If you import CBAM goods for inward processing and later declare the resulting processed products for release for free circulation, the CBAM goods originally entered for inward processing become also subject to reporting. If you import CBAM goods from a third country, you are generally subject to the applicable CBAM reporting obligations, unless you are exempt due to one of the following exceptions.
What exemptions are there to CBAM?

The following exceptions apply to the scope of CBAM in accordance with Article 2 of the CBAM Regulation:

Please note that additional exemptions may exist, but these are not currently relevant.

Certain countries of origin and territories

Products originating in countries that apply the EU ETS 1 or whose emissions trading system is fully linked to the EU ETS 1 are exempt from the application of the CBAM. These countries of origin are listed in Annex III(1) of the CBAM Regulation and, currently, include Norway, Iceland, Liechtenstein and Switzerland. In addition, the CBAM Regulation does not apply to goods originating in the customs exclusion zones of Büsingen, Helgoland, Livigno, Ceuta and Melilla.

Exemption for military purposes

The exemption applies to all goods imported by military authorities of EU Member States or under an agreement with the military authorities of a third country within the framework of the common security and defence policy of the EU or NATO.

Exemption for minor import volumes: De minimis exemption based on the mass-based threshold of 50 tonnes (from 01/01/2026 onwards)

In the definitive regime, on 01/01/2026, a mass-based exemption was introduced for imports of less than 50 tonnes of CBAM goods, with the exception of electricity and hydrogen. Starting from 01/01/2026, imports of CBAM goods (except electricity and hydrogen) with a total annual amount of currently less than 50 tonnes have been exempt from the CBAM obligations (Article 2a of CBAM Regulation). However, where the total quantity of CBAM goods imported from the cement, iron and steel, fertiliser and aluminium industries exceeds 50 tonnes per calendar year and per importer, all CBAM obligations must be fulfilled. This mass-based exemption does not apply to indirect customs representatives or importers of CBAM electricity and hydrogen: the CBAM Regulation obligations apply to them for all imports. A detailed description of how the mass-based threshold value is calculated can be found on our page:

CBAM Definitive Regime from 2026

If you are importing CBAM goods and the exemptions do not apply to you, the next step is to clarify whether or not you are established within the EU.
Who is affected by the CBAM obligations?

If none of the exceptions described above apply to you, the specific obligations depend on whether or not you are established in one of the EU Member States.
Are you established in a Member State of the EU?

You are established in a Member State of the EU (Article 3(19) CBAM Regulation) in one of the following cases:

(a) in the case of a natural person, any individual whose place of residence is in a Member State;

(b) in the case of a legal entity or an association of persons, any person whose registered office, central headquarters or permanent business establishment is in a Member State.

Depending on whether you are established in a Member State, the following constellations may arise:

Case A: You are established in a Member State and import your CBAM goods yourself.

If you submit the customs declaration in your own name and on your own account, you must apply for and obtain the status of an authorised CBAM declarant as an importer in accordance with Articles 5 and 7 of the CBAM Regulation. As an authorised CBAM declarant, you are responsible for fulfilling the CBAM obligations in accordance with Article 4 et seq. CBAM Regulation.

Case B: You are not established in a Member State of the EU.

You must import the CBAM goods via an indirect customs representative. The CBAM obligations automatically apply to them.

Case C: You are established in a Member State and import CBAM goods through an indirect customs representative.

If you import CBAM goods via an indirect customs representative who submits the customs declarations for release for free circulation in his own name but on your account, either you or the indirect customs representative must fulfil the CBAM obligations.
In this case, the internal relationship between the indirect customs representative and the importer must clearly specify which party assumes the CBAM obligations. The indirect customs representative may refuse to assume the reporting obligations (Article 5(1a) of the CBAM Regulation, Article 8(3) of the Implementing Regulation for the reporting obligations applicable in the transitional period (EU) 2023/1773). In this case, he must inform the importer of his CBAM obligations

What are the Obligations in the Transitional Period and in the Definitive Regime?

The following table shows the various obligations in the transitional period and in the definitive regime.

Overview of the obligations in CBAM
	Transitional period (October 2023 to the end of 2025)	Definitive regime (from 01.01.2026)
Reporting obligations	Quarterly submission of CBAM reports Mandatory use of actual emissions values in the reporting from August 2024	Annual submission of CBAM declarations (for the first time on 30/09/2027 for the 2026 calendar year) Free choice between using verified actual emissions or default values in the reporting
Purchase of CBAM certificates		Annual purchase and surrender of CBAM certificates (for the first time by 30/09/2027 for the 2026 calendar year) Obligation to hold CBAM certificates on a continuous basis (quarterly from 2027)
Authorisation	No authorisation required for the import of CBAM goods.	Authorisation required to import CBAM good For more information, please visit our Authorisation page and also note the regulations on provisional import at the beginning of 2026. Authorisation for the CBAM definitive regime
Exemptions	Exemptions for imports under 150 euros Exemptions for imports for military purposes Exemptions for certain countries of origin Exemptions for electricity imports	Exemptions due to mass-based threshold of 50 tonnes total mass per calendar year Exemptions for imports for military purposes Exemptions for certain countries of origin Exemptions for electricity imports Temporary exemption due to application for authorisation (Article 17(7a) of the CBAM Regulation)