CBAM’s first real year. The bill is small; the data is not.

The EU’s Carbon Border Adjustment Mechanism moved from reporting to paying on 1 January 2026. Imports of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity now carry a carbon cost, priced against the EU Emissions Trading System.

Nothing has been paid yet, which is why many businesses have not felt it. That changes next year.

The dates that matter

• 1 January 2026. The definitive regime began. Only an authorised CBAM declarant may import covered goods above the threshold. Importers who applied by 31 March 2026 may keep importing while their application is decided; anyone else needs authorisation before the goods arrive.
• 50 tonnes a year. Importers whose total covered imports stay under 50 tonnes a year are outside the charge. Above it, every tonne counts. Hydrogen and electricity are not covered by the threshold.
• 1 February 2027. CBAM certificates for 2026 imports go on sale.
• 30 September 2027. The first annual declaration is due, and certificates covering 2026’s embedded emissions must be surrendered.

For 2026, the certificate price is the quarterly average of the EU ETS auction price for the quarter in which the goods were imported.

The number of certificates is reduced to reflect the free allowances EU producers still receive. In 2026 that leaves only a small share of embedded emissions to pay for. The share rises every year until free allocation ends in 2034, so the first bill understates what the same imports will cost by the end of the decade.

Why the data is the cost

The charge depends on the emissions embedded in each product. An importer can use actual emissions, verified at the installation that made the goods, or the Commission’s default values, which are set deliberately high. A steel or aluminium buyer without verified data from its mill pays for a worse carbon position than it may have.

So the commercial question is whether your suppliers can name the installation behind each shipment and give you verified emissions for it. Many trading intermediaries cannot, because they do not know which mill made the goods.

Who outside the EU is affected

A UK exporter selling steel or aluminium products into the EU will be asked by its EU customers for installation-level emissions data. Exporters who can supply it keep their customers’ costs down. Those who cannot become the more expensive supplier, whatever their price per tonne. There is no link yet between the UK and EU carbon markets, and no exemption for UK goods. The UK’s own carbon border mechanism starts on 1 January 2027 for aluminium, cement, fertiliser, hydrogen, and iron and steel, with registration for importers of £50,000 or more of covered goods a year.

What to check now

• Your 2026 volumes of covered goods, by CN code, against the 50-tonne threshold.
• Which installation made each shipment, and whether the supplier will give you verified emissions for it.
• Who carries the cost in your contracts: buyer, seller or intermediary.
• A cash estimate for certificates on 2026 imports, and for the same volumes in 2028 and 2030, using default values as the worst case.