What CBAM Is Designed to Do
CBAM is an EU regulation that puts a carbon price on specific goods entering the EU. European producers already pay for their emissions under the EU Emissions Trading System. CBAM makes sure that imported products face a comparable cost, so that production does not simply shift to countries with looser climate rules.
For importers, that translates into three concrete obligations: get authorised, report the embedded emissions and surrender the right number of CBAM certificates every year.
Which Goods Fall Under CBAM
The scope is deliberately focused on carbon-intensive products. CBAM currently applies to six categories:
- Iron and steel
- Cement
- Fertilisers
- Aluminium
- Electricity
- Hydrogen
Whether a specific product is covered comes down to its CN code, the customs classification you already use for your import declarations. Annex I of the CBAM regulation lists every CN code in scope. It pays to check this carefully, because the list also includes many processed and semi-finished products, such as screws, bolts, tubes and other articles made of steel or aluminium.
The 50-Tonne Threshold
Not every importer is affected. CBAM applies when the goods are produced outside the European Economic Area (EEA) and Switzerland, and when you import more than 50 tonnes of CBAM goods per year. That threshold is based on weight, not value, which means a company importing heavy steel components can cross it faster than expected.
There is one important exception. Hydrogen and electricity are always covered, regardless of volume. Even a single small consignment brings you under the rules.
How to reduce the impact for your business? Please contact team Trasegro.
Who Carries the Responsibility
The party responsible for CBAM obligations is called the authorised CBAM declarant. In most cases, that is the importer. When goods are cleared through indirect customs representation, either the importer or the indirect representative can take on this role.
For companies based outside the EU, the picture is simpler: the indirect representative is always the CBAM declarant. And an indirect representative acting as declarant always needs an authorisation, even when the volumes stay below 50 tonnes.
This makes clear agreements with your customs partner essential. Who applies for the authorisation, who submits the declaration and who buys the certificates should be settled long before the first shipment arrives at the border.
Authorisation Comes First
If you expect to import more than 50 tonnes of CBAM goods per year, or any hydrogen or electricity, you need an authorisation before the goods are imported. Without it, the goods cannot be released into the EU. In practice, a missing authorisation means cargo waiting at the port or terminal, with storage and demurrage costs adding up while the paperwork catches up.
Annual Declaration and Certificates
Once authorised, the declarant submits a CBAM declaration every year covering the goods imported in the previous calendar year. This declaration is mandatory when more than 50 tonnes were imported. It includes the quantity of CBAM goods and their embedded emissions: the CO2 released during their production.
Those emissions are paid for with CBAM certificates. The declaration states how many certificates you need to surrender, and both the declaration and the certificates are due before 1 October each year. For imports made in 2026, that means before 1 October 2027. Declarants also need to make sure they have purchased enough certificates in advance, rather than scrambling at the last minute.
Everything runs through the CBAM registry of the European Commission. Dutch companies log in with eHerkenning at level 3, so it is worth checking now whether the right people in your organisation have access.
Not sure what CBAM means for your shipments? Please contact team Trasegro.
What This Means for Your Supply Chain
CBAM is not just a reporting exercise. It changes how you compare suppliers. A lower purchase price from a high-emission producer may end up costing more once certificates are added. Reliable emissions data from your suppliers becomes just as important as price and lead time.
A few practical steps make a real difference:
- Check the CN codes of everything you import against Annex I.
- Calculate your annual tonnage per category to see whether you cross the 50-tonne threshold.
- Agree with your customs representative who acts as CBAM declarant.
- Ask suppliers outside the EU for verified emissions data on the goods they deliver.
- Include certificate costs in your budgets and pricing for 2026 and beyond.
Companies that prepare now avoid delays at the border and unpleasant surprises when the first bill arrives in 2027.
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