CBAM in 2026: affected importers, thresholds, and early figures
As of January 1, 2026, the EU’s Carbon Border Adjustment Mechanism (CBAM) has entered its definitive regime, following the Commission’s formal confirmation of the system’s start date. For EU importers of carbon-intensive goods — including iron & steel and aluminium — CBAM is no longer a “reporting pilot”: it becomes a formal compliance system.
The key point for 2026: liability starts now, payment starts later
Imports made in 2026 generate a CBAM financial liability, but CBAM certificates are not sold in 2026. Under the CBAM simplification package published in October 2025, the sale of CBAM certificates starts in February 2027, and the first annual declaration + certificate surrender for 2026 imports is due by 30 September 2027.
Who is affected in 2026: fewer importers, but the heavyweights remain
During the transitional phase (2023–2025), around 200,000 importers were involved in CBAM reporting, many of them smaller traders.
From 2026, a single mass-based exemption threshold of 50 tonnes per year removes many low-volume importers from CBAM obligations. The Commission estimates this exempts ~182,000 importers while still covering over 99% of emissions in scope.
Implementation struggles
From January 2026, importers above the threshold must operate as Authorised CBAM Declarants. Those who submit their application by 31 March 2026 may continue importing CBAM goods while awaiting authorisation. The Commission has clarified that applications should be submitted prior to import or, at the latest, by that date.
EUROMETAL President Alexander Julius has highlighted serious implementation difficulties for steel importers, pointing to cost surprises and operational strain as companies digest late-released technical requirements.
Commission “emergency brake”: Article 27a
In January 2026, the European Commission clarified that it may invoke the proposed Article 27a to temporarily remove certain goods from CBAM scope in cases of severe harm to the EU internal market due to serious and unforeseen circumstances, such as price shocks. If adopted, this mechanism could be applied retroactively to cover imports from 1 January 2026.
Producers’ critique: loopholes and backfire risk
EUROFER has argued that CBAM still contains structural loopholes and warned that, without broader fixes, it could backfire by penalising European steelmakers and customers attempting decarbonisation amid overcapacity, high energy costs and unfair trade practices.
Early figures
In its January 14, 2026 update, the European Commission stated that by January 7, over 12,000 operators had applied for CBAM authorisation, more than 4,100 had obtained authorised declarant status, and 10,483 import customs declarations with CBAM goods were validated automatically in real time. In the first reporting window (January 1–6), declarations covered 1,655,613 tonnes, overwhelmingly iron & steel (98%), with main origins in Türkiye, China, India, Canada, Taiwan, and Vietnam, and the highest declaration volumes recorded in Belgium, Spain, Romania, the Netherlands, France, and Germany.
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