OpenBtoB guide
CBAM certificates from 1 February 2027: what steel and aluminium exporters must give their EU buyers
Informational, not legal advice: verify with a licensed customs broker. Every duty rate on this page is an estimate, not legal advice. Facts on this page were last checked on 2026-10-13 against EUR-Lex and the European Commission's CBAM pages.
If you make or sell iron, steel or aluminium goods to the EU, an EU buyer above the 50-tonne yearly threshold now carries a carbon cost on those imports. The EU Carbon Border Adjustment Mechanism (CBAM) is in its definitive period since 1 January 2026, and the CBAM certificates that pay for 2026 imports go on sale on 1 February 2027. Your buyer will ask you for emissions data to keep that cost down. This page explains the dates, who is exempt, which goods are covered, and what to prepare.
CBAM is not a customs duty. It is an obligation of the EU importer, separate from the duty rate and the import VAT.
The dates
| Date | What happens |
|---|---|
| 1 January 2026 | CBAM definitive period begins. Only an authorised CBAM declarant may import covered goods above the threshold. |
| 31 March 2026 | Importers that applied for authorisation by this date may keep importing while their application is decided. |
| 1 February 2027 | Member States start selling CBAM certificates on the common central platform. Certificates bought in 2027 cover the emissions embedded in 2026 imports. |
| From 2027, each quarter end | An authorised declarant must hold certificates for at least 50% of the embedded emissions of the goods imported since the start of the year. |
| 30 September 2027 | First annual CBAM declaration (for 2026 imports) and first surrender of certificates. Then every 30 September. |
| 31 October each year | Last day to ask the Member State to buy back excess certificates. |
The 50-tonne threshold: who is exempt
Regulation (EU) 2025/2083 replaced the old value-based exemption with a single mass-based threshold of 50 tonnes of net mass per importer per calendar year. It counts all CBAM goods of iron and steel, aluminium, fertilisers and cement together. It does not apply to electricity or hydrogen.
- An importer that stays at or below 50 tonnes in a year has no CBAM obligations for that year.
- An importer that goes above 50 tonnes becomes subject to all obligations for all the CBAM goods it imported that calendar year, from the first tonne.
- An importer that expects to exceed the threshold must apply to become an authorised CBAM declarant before it imports.
What this means for you: a small buyer that imports a few tonnes of bolts a year may be exempt. A distributor that imports containers of profiles is not. Ask your buyer which side of the line it is on before you build an emissions file for it.
Which goods are covered
CBAM covers the goods listed in Annex I of Regulation (EU) 2023/956, by EU Combined Nomenclature (CN) code. For iron, steel and aluminium:
- Iron and steel: chapter 72 (with exceptions, among them ferro-alloys of 7202 and ferrous scrap 7204), plus 2601 12 00 (agglomerated iron ores) and the articles of headings 7301, 7302, 7303 00, 7304, 7305, 7306, 7307, 7308, 7309 00, 7310, 7311 00, 7318 (screws, bolts, nuts, washers) and 7326.
- Aluminium: 7601, 7603, 7604, 7605, 7606, 7607, 7608, 7609 00 00, 7610, 7611 00 00, 7612, 7613 00 00, 7614 and 7616. Aluminium scrap (7602) and 7615 (household articles) are not listed.
Cement, fertilisers, electricity and hydrogen are also CBAM goods; this page covers steel and aluminium only.
The HS lookup shows a CBAM flag on covered EU lines, with its legal reference:
- Screws and bolts 7318.15 from Vietnam to the EU: CBAM (iron and steel) flag.
- Aluminium hollow profiles 7604.21 from Vietnam to the EU: CBAM (aluminium) flag.
- Aluminium hollow profiles 7604.21 from China to the EU: CBAM (aluminium) flag, and an anti-dumping flag whose rate depends on the producer.
A lower duty does not remove CBAM. For example, the lookup shows a 0% EVFTA preferential rate for the Vietnamese 7318.15 line and a CBAM flag on the same line (estimate, not legal advice).
What a CBAM certificate costs, and how the price is set
One CBAM certificate covers one tonne of CO2-equivalent embedded emissions. The price follows the EU Emissions Trading System:
- For 2026 imports, the price is the quarterly average of EU ETS allowance auction prices for the quarter in which the goods were imported. The Commission publishes it after each quarter: EUR 75.36 for Q1 2026 (published 7 April 2026), EUR 75.28 for Q2 2026 (6 July 2026) and EUR 82.32 for Q3 2026 (5 October 2026). The Q4 2026 price is due on 4 January 2027.
- From 2027, the price is a weekly average.
These are the Commission's published certificate prices, not the cost of your goods. The number of certificates your buyer must surrender depends on the emissions embedded in the goods, any carbon price already paid in the country of production, and other adjustments in the regulation. This page does not estimate a cost per tonne of goods.
What your EU buyer will ask you for
Your buyer declares the embedded emissions of the goods. It can use actual emissions from your installation, or the Commission's default values. Which of the two gives your buyer the lower figure depends on your installation, so expect the question. For iron, steel and aluminium goods only direct emissions count; indirect emissions (from electricity) count for cement and fertilisers.
Prepare:
- Installation identification: the name and location of the installation that made the goods, and an operator contact.
- Specific embedded emissions of each product (tonnes of CO2e per tonne of goods), with the method used to determine them.
- A verification report: actual emissions must be verified by a verifier accredited under the CBAM rules. Without it, your buyer falls back to default values.
- Any carbon price effectively paid in the country of production, with proof. The buyer can claim a reduction only for a carbon price that was actually paid.
A non-EU operator can register its installation in the CBAM registry and share its verified data with its declarants directly, instead of sending it to each buyer separately.
What this page does not cover
- The downstream extension. The Commission proposed on 17 December 2025 to extend CBAM to some steel- and aluminium-intensive downstream goods and to add anti-circumvention rules (procedure 2025/0419(COD)). It is a proposal, not law: on the last check the European Parliament had referred it back to committee for negotiations. Nothing on this page assumes it.
- Cement, fertilisers, electricity and hydrogen.
- The customs duty and VAT on your goods: see our Vietnam to EU route guide.
- A cost estimate for any shipment.
Check your own line
Use the HS lookup: enter your code and choose the EU member state of import. CBAM covered lines show a CBAM flag with its legal reference and the 50-tonne condition. An "ex" code covers only part of a line: check your product against Annex I. All guides are listed on Guides. Sign up to save your codes.
FAQ
Is CBAM a customs duty? No. It is an obligation of the EU importer to declare embedded emissions and surrender certificates. The customs duty and import VAT apply separately.
Does my EU buyer need certificates if it imports less than 50 tonnes a year? No. An importer whose CBAM goods of iron and steel, aluminium, fertilisers and cement stay at or below 50 tonnes of net mass in a calendar year is exempt for that year. Above 50 tonnes, all its CBAM imports of that year count.
When are the first certificates bought and surrendered? Certificates go on sale on 1 February 2027. The first declaration and surrender, for 2026 imports, are due by 30 September 2027.
Are aluminium household articles (7615) covered? Not under Annex I as it stands. Check the Commission's downstream proposal before relying on that for later years.
Sources
Primary sources, checked on 2026-10-13.
- Regulation (EU) 2023/956, CBAM: Annex I goods, Articles 4, 7 to 10, Annex II and Annex V
- Regulation (EU) 2025/2083, simplification amendment: 50-tonne threshold, 1 February 2027 sales, 30 September declaration and surrender
- Implementing Regulation (EU) 2025/2548, certificate price calculation: quarterly average for 2026, weekly from 2027
- European Commission, CBAM and the definitive regime
- European Commission, price of CBAM certificates: EUR 75.36 (Q1 2026, published 7 April 2026), EUR 75.28 (Q2, 6 July 2026), EUR 82.32 (Q3, 5 October 2026)
- European Parliament, procedure 2025/0419(COD): downstream extension proposal
- CBAM flags and duty rates: the OpenBtoB HS lookup, EU data as of 2026-09-15 (estimate, not legal advice)
Published 2026-10-13. Last updated 2026-10-13.