Knowledge Base · Compliance & Tax

EU CBAM Guide 2026: Definitive-Period Rules and What Chinese Exporters Must Do

The CBAM transitional period ended on 1 January 2026. This guide covers the authorised declarant system, annual declarations replacing quarterly reports, the certificate purchase and surrender timeline, actual vs default embedded emissions, the 50-tonne de minimis exemption, cost modeling — and an action checklist for exporters of steel, aluminium, cement, fertilisers and hydrogen to the EU.

Updated 2026-10-07 ~8 min read Mighty International Trade Team

Key takeaway

Confirm the CN code, importer authorisation and emissions-data route before agreeing cost allocation. Covered 2026 imports already incur definitive-regime obligations; purchasing and the first annual filing take place in 2027. The 50-tonne exemption is annual per importer, not per shipment, and excludes electricity and hydrogen.

1. What CBAM does

CBAM connects embedded emissions in specified imports to the EU carbon-pricing framework. Regulation (EU) 2023/956 establishes the mechanism and Regulation (EU) 2025/2083 simplifies it. Separate implementing rules govern calculation, verification and free-allocation adjustment. This guide was checked against the official sources below on 6 October 2026.

2. Scope and the 50-tonne threshold

Start with the CN codes listed in Annex I: cement, electricity, fertilisers, iron and steel, aluminium, hydrogen and specified downstream goods. A Chinese export HS code does not replace full EU CN classification.

  • The 50-tonne threshold aggregates the net mass of relevant iron and steel, aluminium, fertiliser and cement imports by the same importer over a calendar year. It is not a separate allowance for each sector, supplier or consignment.
  • Electricity and hydrogen are excluded from this mass-based exemption. Check any origin-based or other exemption separately.
  • Exceeding the threshold brings the relevant whole-year imports into the obligations, not just the excess. Apply for authorisation before an expected breach.

3. The declarant and the supplier

The authorised CBAM declarant handles annual reporting and certificate surrender. This may be the EU importer or an indirect customs representative legally accepting that role. Chinese producers and exporters coordinate product, installation, precursor and emissions information with that party. Arranging transport does not automatically make a forwarder the CBAM declarant.

A DDP contract should identify the importer, representation arrangement, data deadlines, verification costs and certificate-cost allocation. Contractual payment responsibilities and statutory accountability must each be settled.

4. Definitive-regime milestones

  • 1 January 2026: the definitive regime begins, bringing obligations and associated carbon costs for covered imports.
  • Authorisation transition: importers or representatives that applied by 31 March 2026 may continue importing while awaiting a decision under the applicable provisions. An unconditional ban on all pending applicants from 1 April would be incorrect.
  • 1 February 2027: certificate sales begin; the liability for relevant 2026 imports remains.
  • 30 September 2027: the first annual declaration and certificate surrender for 2026 imports are due.

5. Actual emissions and default values

Use the product and process boundaries in Implementing Regulation (EU) 2025/2547. Annex II goods, including iron and steel, aluminium and hydrogen, currently account for direct emissions only. Apply the relevant indirect-emissions rules to sectors such as cement and fertilisers; electricity has specific methods. A generic product footprint or an installation's entire electricity footprint is not automatically its CBAM emissions figure.

Actual values require accredited verification under the applicable rules. Select default values for the correct origin, product, year and annex. The Commission lists Regulation (EU) 2025/2621 and the correcting Regulation (EU) 2026/1740; its spreadsheet is for information, while the legislation is authoritative. Published defaults may already incorporate the prescribed adjustments: do not add a universal extra 30%. Compare available data, applicable defaults and verification costs before selecting a route.

6. Cost estimates are not a flat 2.5% calculation

Calculation approach

Calculate embedded emissions from quantities and the applicable specific emissions, apply the free-allocation adjustment under Regulation (EU) 2025/2620, and handle any eligible carbon-price deduction to determine the certificate requirement. For 2026 imports, the certificate price reflects the relevant import quarter's EU ETS auction-price basis. Check the pricing rules separately for later years.

The 2026 phase-in must not be simplified to “every producer's actual emissions multiplied by 2.5%”. The free-allocation adjustment depends on product benchmarks and prescribed methods; high-emissions products can face a materially different effective burden.

Budgeting boundaries

Separate quantity, actual or default emissions, free-allocation adjustment, deductible carbon price, certificate price and verification fees in the budget. Leave unknown inputs pending and test price sensitivity. Without the relevant factory data and product benchmark, a fixed per-tonne carbon-cost promise is unreliable.

7. Exporter's checklist

  1. Confirm CN classification, origin, annual cumulative net mass and authorisation with the EU importer.
  2. Map goods to production installations and agree the actual-value or default-value route; book accredited verification where needed.
  3. Reconcile descriptions, quantities and net weights across invoices, packing lists and customs declarations. Track data versions and owners.
  4. Agree data delivery, corrections, confidentiality and cost allocation in the contract, especially for DDP sales.
  5. Keep relevant carbon-price payment and compensation records for the declarant's deduction assessment.
  6. Recheck legislation and default-value corrections before shipment.

8. How Mighty can help

We can coordinate transport documentation, EU customs-agent communication and shipping arrangements. Emissions calculations, accredited verification and CBAM declarations remain with the appropriate responsible parties and specialists. Share the product, code, net weight, production location, destination and trade terms so we can define the logistics support required.

Preparing an EU shipment?

Confirm the importer and data route before booking and document preparation.

Discuss your shipment

9. Official registry access

Use the Commission's CBAM Registry guidance and the importing country's competent authority for authorisation and system access. Distinguish proposals from rules already in force.

Frequently asked questions

How do I determine whether my goods are covered?

Match the EU CN code against Annex I to Regulation (EU) 2023/956 and its amendments, then check origin and exemptions. Cement, electricity, fertilisers, iron and steel, aluminium and hydrogen are covered sectors, but not every product in those sectors is included. The 50-tonne annual net-mass threshold aggregates relevant imports per importer in four sectors: iron and steel, aluminium, fertilisers and cement. It does not apply to electricity or hydrogen.

Who is responsible for CBAM?

The authorised EU importer or an indirect customs representative legally acting in that role handles declarations and certificate surrender. Chinese suppliers support the product, installation and emissions data. DDP allocates contractual responsibilities but does not itself confer CBAM authorisation or replace the statutory declarant.

Must certificates be bought in 2026?

Imports in 2026 already fall within the definitive regime and carry the associated financial liability. Certificate sales start on 1 February 2027; the first annual declaration and surrender deadline for 2026 imports is 30 September 2027. Deferred purchasing does not make 2026 imports free of carbon costs.

Should we use actual emissions or default values?

Where permitted, use actual values verified by an accredited verifier or the applicable Commission default values. Match the product, origin, year and calculation boundaries, including corrections. Do not apply a universal extra 30% multiplier or assume actual emissions are always lower.

Can a carbon price already paid be deducted?

The authorised declarant may request a reduction in certificates where the effective payment, evidence and certification requirements are met, allowing for rebates or compensation. With default emissions, the applicable route uses yearly default carbon prices where available. Domestic compliance records alone do not establish a full deduction.

Official references and scope

Checked 6 October 2026. Consult the act and its amendments together; a source listing is not an individual customs or verification decision.

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