Since 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM) has operated under its definitive regime. Companies importing iron and steel, aluminium, cement, fertilisers, electricity or hydrogen into the EU no longer just report emissions: imports made in 2026 already create a financial obligation, even though actual payment only starts in 2027.

This article sets out the real CBAM timeline, the obligations of the authorised CBAM declarant, and a point often missing from existing coverage: the mirror effect of CBAM on suppliers based outside the EU, particularly in Tunisia and Morocco, whose European customers now require precise embedded-emissions data.

Table of contents

What is CBAM?

The Carbon Border Adjustment Mechanism (CBAM) is established by Regulation (EU) 2023/956 of the European Parliament and of the Council. It applies a carbon price to goods imported into the EU equivalent to the price paid by EU producers under the EU Emissions Trading System (EU ETS), to prevent carbon leakage: without an adjustment mechanism, an EU-based company could relocate production to a country with less stringent climate rules, or replace a product made in the EU with a cheaper, more carbon-intensive import.

The regulation distinguishes two periods: a purely declarative transitional phase from 1 October 2023 to 31 December 2025, and a definitive regime applicable since 1 January 2026, which introduces the obligation to purchase and surrender certificates.

The current scope covers six sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. The Commission has proposed extending this scope to refining, chemicals and certain downstream products (COM(2025) 989), but this text is not adopted to date: only the six current sectors are covered.

Who must become an authorised CBAM declarant?

Since 1 January 2026, any importer (or its indirect customs representative) exceeding the de minimis threshold must apply for authorised CBAM declarant status with the national competent authority in its Member State of establishment. This status is required to access the CBAM registry, purchase CBAM certificates and surrender them.

An importer who exceeds the threshold during the year becomes retroactively liable for all embedded emissions in all goods imported that calendar year, not only for the portion above the threshold. This point could not be cross-checked against the consolidated regulation text (EUR-Lex blocks automated requests): to be confirmed legally before being relied on contractually.

The CBAM timeline 2023-2027

CBAM's timeline unfolds across several distinct milestones that are easy to conflate:

  • 1 October 2023: CBAM's transitional phase enters into application. Importers report embedded emissions quarterly, with no financial obligation.
  • 31 December 2025: end of the transitional phase.
  • 1 January 2026: the definitive regime enters into application. Authorised declarant status becomes mandatory above the de minimis threshold. Imports from this date create a financial obligation, though no certificate is purchased yet.
  • 1 January 2027: the quarterly certificate-holding obligation enters into application. At the end of each 2027 quarter, certificates held must cover at least 50% of embedded emissions imported since the start of the year (threshold lowered, see below). It does not apply to 2026 imports.
  • 1 February 2027: Member States open the sale of CBAM certificates on a common central platform. Authorised declarants then retroactively purchase the certificates for their 2026 import emissions.
  • 30 September 2027: deadline for the first annual CBAM declaration and surrender of certificates for 2026 emissions, a deadline that then recurs every year for the preceding calendar year.

An import made in March 2026 therefore triggers a carbon liability in 2026, but its actual settlement only happens between February and September 2027.

The simplification regulation (EU) 2025/2083

CBAM as adopted in 2023 has since been amended several times. The text carrying the most significant adjustments is Regulation (EU) 2025/2083 of 8 October 2025, amending Regulation (EU) 2023/956 as part of the "Omnibus" regulatory simplification work launched by the Commission in early 2025.

A note of caution: a separate text, Implementing Regulation (EU) 2024/3210 of 18 December 2024, deals only with the technical rules of the CBAM registry, not with the changes described below. The two texts are sometimes confused in publicly available summaries.

Regulation (EU) 2025/2083 introduces three major changes:

  • A 50-tonne de minimis threshold, based on the cumulative net mass of goods imported by a given importer during a calendar year, applying cumulatively to iron and steel, aluminium, fertilisers and cement. Below this threshold, the importer is exempt from CBAM obligations for that year. Electricity and hydrogen are excluded from this threshold: these imports remain subject to CBAM regardless of quantity.
  • A reduction of the quarterly certificate-holding obligation, from 80% to 50% of embedded emissions imported since the start of the calendar year, judged insufficiently calibrated by lawmakers. It enters into application on 1 January 2027 and does not apply to 2026 imports.
  • The postponement to 1 February 2027 of the opening of certificate sales, to give authorised declarants time to prepare, with a first surrender deadline of 30 September 2027 for 2026 emissions.

Primary source consulted: Regulation (EU) 2025/2083, EUR-Lex.

Default values and certificate pricing

For declarants without verified actual emissions yet, CBAM provides default values set by Implementing Regulation (EU) 2025/2621. On 20 July 2026, the Commission corrected this text via Implementing Regulation (EU) 2026/1740, updating these default values (the tool's functioning is unchanged). France's DGEC reflected this correction in its MACF calculator (`Calculatrice_redevance_MACF_v26_09_04.xlsx`), updated on 4 September 2026 and presented as strictly informational: the French state's liability is not engaged on its results.

Certificate pricing does not follow the same rule in 2026 and from 2027 onward. In 2026, it is set quarterly by the Commission, applicable on the date the goods are released for free circulation: €75.36 for Q1, €75.28 for Q2. The Q3 price was not yet published as of 11 September 2026. From 2027, pricing becomes weekly (average of EU ETS auction prices from the previous week). These prices, published by the Commission, are unrelated to any Kabaun commercial offer.

Verification and surrender of certificates

A declarant can file its annual declaration using default values or actual values. Reporting actual values requires certification by an accredited verifier, under the framework set by Implementing Regulation (EU) 2025/2546 and Delegated Regulation (EU) 2025/2551 of 20 November 2025. Accreditation of verification bodies has started at EU level, with the first accredited verifiers expected around autumn 2026, but their reports will only be usable by declarants from January 2027: for 2026, the DGEC therefore recommends budgeting on the basis of default values.

Each year in September, the authorised declarant surrenders the certificates corresponding to the previous year's imported emissions. If certificates purchased exceed those to be surrendered, a refund can be requested before November of the reporting year, within the limit set by the CBAM regulation (exact cap not verified).

For importers established in France

Authorised declarant status is requested on the MACF 2.0 registry, processed by the DGEC (competent authority), with French customs (DGDDI) handling the customs clearance side. Once validated, the status takes the form of an account number in the format `CBAM-FR-20XX-ABC01234567891`. The Pôles Actions Économiques (PAE) are the customs points of contact for importers. The DGEC runs regular webinars, including one on 28 April 2026 dedicated to the obligations entering into application in 2027.

CBAM from the perspective of non-EU suppliers

Most CBAM content available online addresses EU importers. But the mechanism creates a mirror effect for their suppliers based outside the EU, particularly Tunisian and Moroccan producers of cement, steel, aluminium or fertilisers that export to the EU.

To keep selling to their European customers, these suppliers must now provide the actual embedded emissions of their products, with enough detail for the importer to use in its declaration. Without verified data, the importer applies default values, generally less favourable than the actual emissions of a well-performing site.

An exporter who precisely documents its embedded emissions holds a concrete commercial argument: reducing its European customer's CBAM compliance cost. This angle remains largely untreated, despite directly shaping export competitiveness into the EU.

For more on the carbon regulatory framework applicable in these two countries (French-language resources):

How Kabaun supports CBAM compliance

Calculating the embedded emissions of an imported product falls, for the EU company, under upstream Scope 3. Kabaun covers Scopes 1, 2 and 3 across the 15 GHG Protocol categories, using a calculation engine built on more than 270,000 emission factors from 8 public databases.

For companies, whether EU-based or exporting into the EU, that need a detailed product footprint rather than an organisational carbon footprint, Kabaun offers a dedicated module aligned with ISO 14067 (product carbon footprint / LCA). Data can be imported from CSV or Excel files provided by suppliers, with an AI-assisted column-mapping tool, and Kabaun can automate supplier follow-up requests to improve data reliability. Results are exportable as PDF or Excel reports, usable as supporting evidence in a CBAM declaration.

Kabaun does not produce the CBAM declaration itself and does not purchase CBAM certificates: these steps remain the responsibility of the authorised declarant, via the CBAM registry.

Further resources

FAQ · Frequently asked questions about CBAM

What is CBAM? An EU scheme established by Regulation (EU) 2023/956, applying a carbon price to goods imported into the EU equivalent to what EU producers pay under the EU ETS, to limit carbon leakage.

Who must become an authorised CBAM declarant? Any importer, or its indirect customs representative, exceeding the de minimis threshold of 50 cumulative tonnes over a calendar year. Status is obtained on the MACF 2.0 registry, after processing by the competent authority of the Member State of establishment (the DGEC in France).

Which sectors does CBAM cover? Six sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. An extension to refining, chemicals and certain downstream products has been proposed by the Commission (COM(2025) 989) but is not adopted to date.

When do the first CBAM certificates need to be purchased? Sales open on 1 February 2027, on a common central platform shared by Member States. Authorised declarants then retroactively purchase the certificates for their 2026 import emissions.

What is the price of CBAM certificates in 2026? Set quarterly by the Commission: €75.36 for Q1, €75.28 for Q2. Q3 was not yet published as of 11 September 2026. From 2027, pricing becomes weekly.

Should declarants use default or actual emission values for 2026? Actual-value reporting requires an accredited verifier, whose reports will only be usable from January 2027. For 2026, the DGEC recommends budgeting on default values.

What is the 50-tonne de minimis threshold? A cumulative net mass threshold, introduced by Regulation (EU) 2025/2083, below which an importer is exempt from CBAM obligations for that year. It applies cumulatively to iron and steel, aluminium, fertilisers and cement; electricity and hydrogen are excluded.

Are non-EU suppliers, in Tunisia or Morocco, affected by CBAM? They are not directly liable, as the obligation rests on the EU importer. But their customers now ask them to precisely document their embedded emissions, or risk having less favourable default values applied.

Conclusion

CBAM is no longer just a quarterly report: since 1 January 2026, every import in the covered sectors creates a financial obligation, even though its actual settlement only happens between February and September 2027. Regulation (EU) 2025/2083 eased some constraints (de minimis threshold, quarterly holding reduced to 50%) without changing the overall trajectory, and the implementing acts published since (default values, verification, certificate pricing) now clarify the concrete steps for the authorised CBAM declarant. Companies concerned need to structure their embedded-emissions tracking now, including for their non-EU suppliers.

Kabaun supports you in calculating your Scope 3 emissions and product footprints → kabaun.com/contact