CBAM 2026: how should an importer prepare its data and process?

01

Facts: what changed on 1 January 2026?

The definitive period of the EU Carbon Border Adjustment Mechanism began on 1 January 2026. CBAM covers goods specified in the legislation in the cement, iron and steel, aluminium, fertiliser, electricity and hydrogen sectors. Quarterly transitional reporting has been replaced by authorised-declarant status, an annual declaration and the obligation to surrender CBAM certificates.

The first annual declaration will cover imports made in 2026. The Commission identifies 30 September 2027 as the deadline both for submitting the declaration and surrendering the corresponding certificates. Certificates reflect embedded emissions, taking account of the EU ETS free-allocation rules and a potential reduction for a carbon price effectively paid in a third country where the importer holds the required evidence.

This material was checked on 8 October 2026. It provides general operational information, not individual legal, customs or tax advice. The obligations depend on factors including the CN code, origin, customs procedure, volume and representation model; borderline cases should be confirmed with the appropriate specialist or authority.

02

Facts: how does the 50-tonne threshold work?

The de minimis threshold is 50 tonnes of net mass per importer in a calendar year. The assessment aggregates covered CBAM goods in the iron and steel, aluminium, fertiliser and cement sectors, including goods under different CN codes and across multiple customs declarations. It is not a separate allowance for each code, supplier or shipment.

The mass-based threshold does not apply to electricity and hydrogen. Obligations for those goods need to be assessed regardless of quantity. The exemption should also not be confused with an absence of data duties: without continuous mass tracking, a business may identify the crossing only after goods have cleared customs.

Polish PUESC explains that once the 50-tonne threshold is exceeded, obligations extend to embedded emissions in all threshold-covered goods imported by that entity in the year, not only the amount above the limit. The control therefore needs to cover the full year and retain records from the first import.

03

Facts: who may import and where is the application filed?

An importer subject to the obligation should act as an authorised CBAM declarant or, in the appropriate model, through an authorised indirect customs representative. Applications and decisions are handled electronically in the Authorisation Management Module of the CBAM Registry. Access to EU services requires an EU Login account with two-factor authentication.

Polish PUESC states that from 1 April 2026 simply filing a new application does not permit the applicant to continue importing goods subject to the obligation. Import is possible after status is granted, subject to the threshold and representation rules. The transitional arrangement concerned applications filed by 31 March 2026.

Operationally, a CBAM account number or the reference of a qualifying application needs to be connected to the customs process. Responsibility should be agreed between purchasing, the customs agent, finance and the person managing the CBAM Registry before goods reach the border.

04

Facts: actual values, default values and certificates

For the first declaration, an importer may use default values made available under the CBAM rules or actual values. Using actual values requires data on total embedded emissions from the producer and verification by an accredited verifier. In 2026, the Commission published dedicated resources for installation operators and sector-specific calculation guides.

The CBAM certificate price is linked to the price of EU ETS allowances. In 2026, the Commission calculates it as a quarterly average of auction closing prices; from 2027 the calculation is intended to be weekly. Quantity and emissions data should therefore also feed a financial forecast even though final compliance occurs later.

Where a carbon price has effectively been paid in the country of origin, a corresponding reduction in certificates may be available. A supplier’s email is not sufficient evidence by itself: the business should define the required documents, currency conversion and confirmation, and appoint the person who approves them.

05

WEBee recommendation: build one CBAM data register

Start with a controlled register that connects every import line to the customs document, CN code, net mass, country of origin, supplier, producer and installation. Add the declarant identifier, emissions method, reporting period and links to supporting evidence and verification.

The register does not have to begin as a separate application. A protected table with validation and change history can be sufficient if it has one owner, defined sources and periodic review. Where the number of entries is larger, feed it automatically from the ERP, customs system or customs-agent reports to reduce manual re-entry.

• customs declaration number, release date and CN code;
• net mass and sector used for threshold monitoring;
• importer, customs representative, supplier, producer and installation;
• default or actual value and the calculation-method version;
• direct and indirect emissions within the required scope;
• verifier, verification report and completeness status;
• carbon price paid outside the EU and supporting documents;
• approver, review date and correction history.

06

WEBee recommendation: automate the threshold, missing data and exceptions

Reconcile total net mass to customs data monthly, or more often for high volumes. The system should show the annual result for the importer as a whole, not only for individual operational units, warehouses or suppliers. Set alerts before the threshold is crossed, for example at 60, 80 and 90 per cent, without treating those alerts as a legal interpretation.

A separate view should identify gaps: an unknown installation, inconsistent CN code, missing emissions method, expired verification or an unapproved carbon-price document. Every exception needs an owner, deadline and escalation path. This lets the team address a defined gap rather than search for it when preparing the declaration.

ERP or BI integration only creates value after definitions are agreed. The same term — for example mass, producer or country of origin — must mean the same thing to purchasing, the customs agent and the person preparing the declaration.

07

WEBee recommendation: close 2026 with six controls

Do not wait until September 2027. Run the same checks after each month and prepare a reconciled declaration pack after the final import of the year. The timetable should allow time for supplier questions, verification of actual values, corrections and certificate-purchase planning.

WEBee can map source data, design the register and dashboard, automate report imports and introduce completeness controls. Legal assessment of commodity codes, exemptions and the declarant model should remain with a qualified adviser and the competent authorities.

• reconcile every customs declaration to the CBAM register;
• recalculate aggregate mass and document whether the threshold applies;
• confirm the producer and installation for every line;
• close the choice between a default value and a verified actual value;
• check evidence of a carbon price paid in a third country;
• approve responsibilities, dates, Registry access and the certificate forecast.