We import steel but our supplier is in Turkey. Does CBAM apply?

Yes. CBAM applies to the country of origin of the goods, not the country of the supplier. Turkish steel imported into the EU is subject to CBAM. Turkey does not currently have a carbon pricing mechanism that qualifies for a CBAM offset, so the full embedded carbon value is reportable.

Our supplier cannot provide embedded carbon data. What do we do?

Where actual embedded carbon values are unavailable, the definitive default values published in Commission Implementing Regulation (EU) 2025/2621 apply. These are country-specific and product-specific, replacing the world-average defaults used previously. A markup is added: 10% in 2026, 20% in 2027, and 30% from 2028 onwards (fertilisers carry a reduced 1% markup). Using defaults is compliant but not optimal. The rising markup makes obtaining actual data increasingly cost-effective.

What happens when the EU free allocation phase-out is complete?

EU ETS free allocations to EU producers are being phased out between 2026 and 2034 in parallel with CBAM phase-in. As free allocation decreases, the CBAM certificate obligation on importers increases correspondingly. By 2034, importers will bear the full embedded carbon cost with no free allocation offset. This is why certificate budgeting needs to start now.

What are the penalties for non-compliance?

Under the definitive regime, failure to surrender sufficient certificates or to submit a compliant annual declaration carries penalties aligned with the EU ETS penalty regime. Financial penalties are calculated per tonne of CO₂ equivalent. Non-compliance also affects customs risk profiling, meaning your entire import programme may receive increased scrutiny.

Does CBAM apply to goods from non-EU countries only?

Yes. CBAM applies to goods imported into the EU from third countries. Goods produced within the EU are already covered by the EU ETS. Where a carbon price has been paid in the country of origin (e.g., under a recognised carbon pricing scheme), a deduction may be claimed against the CBAM certificate obligation.

EU CBAM · Definitive Regime · Live

EU CBAM is live. Certificates must be surrendered by September 2027. Are your embedded carbon figures ready?

The definitive EU CBAM regime is in force. Quarterly data management, certificate accrual tracking, and your first annual declaration by 31 May 2027 are all live obligations. MyCustomsInfo® has been managing EU CBAM reporting since the transitional period began in October 2023.

Book an EU CBAM compliance review

Operating under EU CBAM since October 2023

CIR 2025/2621 default values applied

Certificate surrender preparation included

Per-client data isolation

Definitive Regime Obligations

What is already required now

The EU CBAM transitional period ended on 31 December 2025. From 1 January 2026, the definitive regime is in force. These are not future obligations. They are current.

Quarterly data management

Embedded carbon data must be collected, validated, and recorded for every consignment of CBAM-covered goods imported into the EU. Where actual supplier data is unavailable, the correct country-specific and product-specific default value from CIR 2025/2621 must be applied with the applicable markup.

Certificate accrual tracking

CBAM certificates must be purchased to cover the embedded emissions in your imports. The first certificate price was published on 7 April 2026 at €75.36/tonne CO₂. You need to track your accruing obligation quarter by quarter to budget for certificate purchases.

Annual declaration by 31 May 2027

The first annual CBAM declaration, covering calendar year 2026 imports, must be submitted by 31 May 2027. Certificates must then be surrendered by 30 September 2027. Missing either deadline carries financial penalties aligned with the EU ETS penalty regime.

CIR 2025/2621 Default Values

The default value problem: why relying on defaults costs more every year

Commission Implementing Regulation (EU) 2025/2621 replaced the world-average defaults used during the transitional period with country-specific and product-specific values. A progressive markup schedule means using defaults is compliant but increasingly expensive.

Three sets of default values

Annex I covers direct emissions, Annex II covers indirect emissions, and Annex III covers electricity. Each value is specific to the country of origin and product category. A material change from the transitional period, which used global averages.

Progressive markup schedule

10% markup in 2026, 20% in 2027, 30% from 2028 onwards. Fertilisers carry a reduced 1% markup due to supply-chain data complexity. The longer you rely on defaults, the more you pay in certificate obligations.

Actual supplier data is always better

Actual embedded emissions data from your suppliers will almost always be lower than the default-plus-markup figure. Pursuing actual data is not just a compliance improvement. It is a cost reduction. MyCustomsInfo® flags every gap and tracks your transition from defaults to actuals.

How to pursue supplier data

Many non-EU suppliers have never heard of CBAM. The engagement process needs to be clear, structured, and persistent. We provide supplier data request templates, track response rates, and help you prioritise which suppliers to engage first based on volume and cost impact.

Certificate Mechanics

CBAM certificate pricing, purchasing, and surrender

CBAM certificate prices are derived from EU ETS auction clearing prices. The first published price was €75.36 per tonne of CO&sub2; (Q1 2026). Quarterly pricing applies in 2026, moving to weekly pricing from 2027. Understanding these mechanics now is essential for budgeting.

How it works

Price derivation. CBAM certificate prices mirror EU ETS auction clearing prices, calculated as a weighted average over the relevant period. Q1 2026 price: €75.36/tonne CO₂.

Certificate purchase. From February 2027, authorised declarants purchase certificates via the CBAM registry. Certificates are bought in advance of the surrender deadline.

Annual declaration. By 31 May each year, importers submit an annual CBAM declaration covering the previous calendar year. This declaration quantifies the embedded emissions and the certificates required.

Certificate surrender. By 30 September each year, the required certificates must be surrendered. Unused certificates can be repurchased by the Commission at the original price.

Free allocation offset. Where EU ETS free allocations apply to the corresponding EU-produced goods, the CBAM certificate obligation is reduced proportionally. Free allocations are being phased out between 2026 and 2034.

Sectors Covered

EU CBAM sector coverage

The EU CBAM currently covers six core product categories, with ceramics and glass included under the expanded scope. If you import any of these into the EU, you have an active CBAM obligation.

Iron and steel

Aluminium

Cement

Fertilisers

Electricity

Hydrogen

Ceramics

Glass

What MyCustomsInfo® Does

Managing your EU CBAM obligations from a single platform

Quarterly report preparation

We extract relevant import data from your declaration history, match it against supplier-provided embedded carbon values, and prepare your quarterly report in the format required by the EU CBAM registry. You review and submit.

Embedded carbon data management

Where supplier data is unavailable, we apply the correct country-specific and product-specific default values from CIR 2025/2621, including the applicable markup. Every data gap is flagged so you can pursue actual supplier data over time.

Certificate surrender preparation

We track your certificate obligation as it accrues, factor in the applicable default-value markups and any free allocation offsets, and provide the figures you need to purchase the right number of certificates at the right time.

Registry compliance support

Authorised CBAM declarant registration, annual declaration preparation, and certificate surrender documentation. We handle the data layer so you can meet every deadline with confidence.

EU CBAM key dates

October 2023

EU CBAM transitional period begins. Quarterly reports required.

31 December 2025

Commission Implementing Regulation (EU) 2025/2621 published. Definitive country-specific and product-specific default values.

1 January 2026

EU CBAM definitive regime in force. 10% default-value markup applies. Annual CBAM declaration due 31 May 2027 covering 2026 imports.

7 April 2026

European Commission publishes first CBAM certificate price: €75.36/tonne CO₂ (Q1 2026, based on weighted average of EU ETS auction clearing prices).

1 February 2027

CBAM certificate purchases open. Authorised declarants begin buying certificates to cover 2026 imports.

31 May 2027

First annual CBAM declaration due (covering calendar year 2026).

30 September 2027

First EU CBAM certificate surrender deadline.

1 January 2028

Default-value markup rises to 30% (and remains at 30% thereafter).

EU CBAM questions

Certificate surrender starts September 2027. Preparation starts now.

Every quarter of embedded carbon data that is not collected and validated now is a quarter of compliance risk and potential cost overrun at surrender time.

Book an EU CBAM compliance review

+44 151 808 0103 • [email protected]

Also importing into the UK? The UK CBAM starts January 2027 with no transitional period.

Read the UK CBAM page