Author: Jenny Mae Vansteenlandt

Do you import goods from outside the European Union, such as steel, aluminium, cement or fertilisers? If so, you’ll be hearing the term CBAM more and more often. For many businesses, this sounds complex and administrative, but in practice the impact is often both financial and operational.

In this article, we explain CBAM: what it is, who it applies to and what you need to do in practice.

What is CBAM?

CBAM stands for Carbon Border Adjustment Mechanism. It is a European system that ensures that goods imported from outside the EU pay a comparable CO₂ cost to goods produced within the EU.

Why is Europe doing this?
Within the EU, large manufacturing companies must pay for their CO₂ emissions via the EU Emissions Trading System (EU ETS). The higher the emissions, the higher the cost. To prevent companies from relocating their production to countries with less stringent climate regulations, Europe is introducing CBAM for imports.

Result
à Importing CO₂-intensive goods will become more expensive
à Products inside and outside the EU are treated more fairly

Which goods does CBAM apply to?

CBAM currently applies to these sectors:

• iron and steel
• aluminium
• cement
• fertilisers
• hydrogen
• electricity

Exactly which goods fall under CBAM is determined on the basis of customs codes (CN codes). This list is laid down in European legislation.

Is your business potentially subject to CBAM?

In many cases, you are subject to CBAM if all of the following conditions are met:

• you import goods from outside the EU;
• those goods fall under CBAM (based on the CN code);
• you are the official importer who submits the customs declaration;
• you import more than 50 tonnes per year, in total across all CBAM goods.
  (There is no threshold for electricity and hydrogen: CBAM always applies to these.)

à Do you import less than 50 tonnes? In that case, you are in principle exempt, but this must be correctly stated in the customs declaration.

1.      What do you need to do if you are subject to CBAM?

CBAM consists of three main parts.
1. Registration and authorisation: From 2026, you will need official CBAM authorisation to import CBAM goods. Without authorisation, imports may be stopped at the border.

2. Data collection and reporting. For each CBAM good, you must keep a record of:

• how many tonnes you are importing;
• the country and production facility from which the goods originate;
• how many tonnes of CO₂ emissions are associated with production.

This information comes from your supplier outside the EU. If your supplier’s CO₂ emissions are not available, default values may be used (which may be significantly higher than the actual values you would receive from your supplier).

3. Purchasing certificates (from 2027)

From 2027, you will need to purchase CBAM certificates:

• 1 certificate = 1 tonne of CO₂
• On 7 April, the European Commission published the first CBAM price for imports in the first quarter of 2026: €75.36 per tonne _{of CO₂}

You must submit these certificates annually with your CBAM declaration.

Why CBAM is more than just administration

CBAM not only impacts reporting, but also:

• purchasing (suppliers with lower emissions become more attractive);
• contracts with suppliers (agreements on emission data and timing);
• budgeting (CBAM certificates have a real cost);
• long-term supply chain choices.

Those who start early will avoid surprises and maintain control over costs.At first glance, CBAM may seem technical and complex, but with the right preparation, it is perfectly manageable. Don’t wait until you have to purchase your first certificates; start thinking today about dates, suppliers and impact.

Do you have any doubts or questions about your situation? A brief analysis is often all it takes to gain clarity. Our experts are happy to assist you, whether you need an initial assessment or comprehensive support towards CBAM compliance and strategic optimisation.