The European Commission has updated its Carbon Border Adjustment Mechanism (CBAM) Q&A guidance, providing further clarity for importers ahead of the regulation’s next implementation phase.
Under the updated framework, importers bringing CBAM-covered goods into the EU from January 1, 2026 will need to be registered as authorized CBAM declarants.
The Commission also confirmed that the 50-tonne annual threshold will apply to most CBAM goods, although hydrogen and electricity imports remain exempt from that limit.
The first annual CBAM declaration will be due by September 30, 2027, covering imports made during the 2026 reporting year. CBAM certificates, which importers must purchase to account for embedded emissions, will become available from February 1, 2027.
Verified emissions data becomes increasingly important
From 2027 onward, authorized declarants will also be required to purchase and hold a minimum number of CBAM certificates each quarter.
The updated guidance places greater emphasis on the use of verified emissions data at the installation level, reflecting the EU’s growing focus on how and where imported goods are produced.
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While importers can still use default emissions values where verified data is unavailable, the Commission noted that these defaults include mark-ups and should not be viewed as a neutral fallback option.
The guidance also reiterates that authorized CBAM declarants remain legally responsible for the accuracy of submitted declarations, regardless of whether emissions data is sourced from suppliers or third parties.
The updates form part of the EU’s broader effort to prepare industries and importers for the full implementation of CBAM, which is designed to place a carbon cost on certain imported goods and prevent carbon leakage as Europe tightens domestic climate policies.
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