CBAM Compliance Hub

CBAM IN 60 SECONDS

Europe prices carbon at its border. Importers of iron & steel (plus cement, aluminium, fertilisers, hydrogen, electricity) pay for the CO₂ embedded in the goods — same price EU mills pay under the ETS.

Only authorised declarants can import. Since 1 Jan 2026, CBAM goods above 50 t/year clear EU customs only for authorised CBAM declarants. No status, no entry.

Emissions data flows from the mill. The producer measures emissions per tonne (verified by an accredited verifier); the importer declares them. No data → punitive default values.

Money moves in 2027. Certificates (1 tCO₂e each, ETS-linked price) go on sale 1 Feb 2027. First declaration & surrender for 2026 imports: 30 Sep 2027.

Which side of the border are you on?

Pick once — the hub remembers and tailors everything below.

YOUR NEXT 6 STEPS — NON-EU MILL / TRADER SELLING INTO THE EU

01Confirm your CN codes are covered (iron & steel Ch. 72–73, incl. precursors like pig iron, DRI, ferro-alloys, pre-consumer scrap).

02Set up installation-level emissions monitoring — direct + precursor emissions, EU methodology.

03Book an accredited verifier: actual values require on-site verification in 2026.

04Issue verified data to your EU buyers in the Commission template — defaults can cost them 5× more, and that cost lands in your price negotiation.

05Log any carbon price paid at home — your buyers deduct it from certificates owed.

06Selling finished goods (fasteners, structures, assemblies)? Map exposure now — downstream scope lands 1 Jan 2028.

START HERE

CBAM Cost Estimator→Country Playbooks→CBAM & Indian Steel Exports Guide→Full Timeline & Deadlines→

THE OBLIGATION SITS WITH YOUR EU BUYER — BUT THE DATA, AND THE COMPETITIVENESS, SIT WITH YOU.

THE MONEY MATHS

Why 2026 feels cheap — and 2034 won't

You only pay for the share of emissions that EU mills no longer get free. That share climbs every year.

CBAM FACTOR — SHARE OF EMISSIONS PAYABLE

20262.5%

20275%

202810%

202922.5%

203048.5%

203161%

203273.5%

203386%

2034100%

ANNEX, REG. 2023/956

WORKED EXAMPLE — ILLUSTRATIVE10,000 t HRC · 2.6 tCO₂e/t · €75.28

Embedded emissions26,000 tCO₂e

2026 · factor 2.5%€48,932 ≈ €4.9/t

2030 · factor 48.5%€949,281 ≈ €95/t

2034 · factor 100%€1,957,280 ≈ €196/t

Same cargo, 40× the levy by 2034 — at a flat carbon price. Cleaner routes and verified actual values are the only levers that shrink it.

Run your own numbers →

CERTIFICATE PRICE — 2026 QUARTERLY

Q1PUBLISHED 7 APR 2026€75.36

Q2PUBLISHED 6 JUL 2026 — LATEST€75.28

Q3DUE 5 OCT 2026—

Q4DUE 4 JAN 2027—

2026 = quarterly average of EU ETS auctions, published the week after each quarter. Weekly prices from 2027. You buy certificates from 1 Feb 2027, retroactively covering 2026 imports.

COUNTRY PLAYBOOKS

The same regulation lands differently in every country

Carbon price at home is deductible from CBAM. Production route drives default-value exposure. Know your position.

IndiaNO DEDUCTION YET

CARBON PRICECCTS compliance market phasing in for steel; no effective carbon price paid yet → nothing to deduct today.ROUTE MIXBF-BOF heavy (~55%) + coal-DRI — high intensity; defaults punitive.DO THISVerified actual values + precursor data are your price weapon. Track CCTS for future deductions.

TurkeyETS PILOT

CARBON PRICETR-ETS pilot live (aligning to CBAM); free allocation heavy → effective price paid ≈ 0 for now.ROUTE MIX~70% EAF scrap — among the lowest embedded emissions of major exporters.DO THISLead with verified actuals; your EAF route is a genuine CBAM cost advantage into the EU.

ChinaPARTIAL DEDUCTION

CARBON PRICENational ETS covers steel since 2024/25; price low (≈ €8–12) → small but real deduction.ROUTE MIXBF-BOF ~90% — high intensity; data sharing can face state constraints.DO THISDocument ETS payments per installation; expect verifier scrutiny on data provenance.

VietnamDEFAULTS RISK

CARBON PRICEPilot ETS scheduled (2025–28), no effective price yet → no deduction.ROUTE MIXNew BF capacity + EAF mix; fast-growing HRC exporter to the EU.DO THISMove early on verified actuals — defaults set from worst emitters erase your margin.

South KoreaK-ETS DEDUCTION

CARBON PRICEK-ETS since 2015 (≈ €6–9 recent); generous free allocation cuts the deductible “price effectively paid”.ROUTE MIXBF-BOF majors + EAF; strong MRV culture — verification is straightforward.DO THISCompute deduction net of free allocation — claiming gross K-ETS price will fail review.

JapanGX TRANSITION

CARBON PRICEGX-ETS turning mandatory FY2026; carbon levy from 2028 → deductions emerging, small at first.ROUTE MIXBF-BOF heavy; high-grade products with strong data systems.DO THISPrepare installation-level actuals now; deduction paperwork matures with GX pricing.

United KingdomLINKING PATH

CARBON PRICEUK ETS ≈ EU levels; UK–EU linkage agreed in principle — linked ETS would exempt UK goods from EU CBAM.ROUTE MIXEAF transition underway (Port Talbot, Scunthorpe plans).DO THISTrack linkage timing; also prepare for the UK’s own CBAM on your imports from 1 Jan 2027.

EU (domestic)REFERENCE

CARBON PRICEFull EU ETS price (~€75); free allocation phasing out 2026–34 in step with CBAM.ROUTE MIXAll routes; benchmark for the “level playing field”.DO THISBuyers: your imported and domestic carbon costs now converge — compare total landed cost, not base price.

INDICATIVE POSITIONS · LAST VERIFIED 18 JUL 2026 · CONFIRM DEDUCTIBILITY WITH YOUR NCA / ADVISER BEFORE FILING

FINISHED GOODS — THE 2028 EXTENSION

Downstream products are next

The Commission's December 2025 proposal extends CBAM to steel- and aluminium-intensive downstream goods — fasteners, structures, mountings, cylinders, radiators and selected appliances — targeted from 1 January 2028, alongside tighter anti-circumvention rules. If you trade finished goods, the clock started for you too.

01Exporters of finished goods: compute the steel/aluminium mass share per product now — the levy will follow the embedded metal.

02Importers: screen your catalogue against the proposed downstream CN list (Ch. 73 articles, mountings, cylinders, radiators, selected appliances).

03Anti-circumvention is tightening in parallel — minimal processing outside the EU will not strip goods of CBAM exposure.

04Contracts signed today for 2028 delivery should already allocate who bears the CBAM cost. Put it in writing.

FULL TIMELINE

DONE

31 DEC 2025

Transitional phase & quarterly reporting end

DONE

1 JAN 2026

Definitive regime live — declarant status required at the border

DONE

6 JUL 2026

Q2 2026 certificate price published — €75.28

5 OCT 2026

Q3 2026 certificate price publication

AHEAD

1 FEB 2027

Certificate sales open on EU central platform

AHEAD

30 SEP 2027

First annual declaration & certificate surrender (2026 imports)

AHEAD

1 JAN 2028

Proposed: downstream finished-goods scope + tighter anti-circumvention

CHANGELOG — 06 JUL 2026: Q2 price €75.28 published · 17 DEC 2025: implementing acts package + downstream proposal · 20 OCT 2025: Omnibus (EU) 2025/2083 in force — 50 t threshold, surrender → 30 SEP, sales → 1 FEB 2027

PLAIN-LANGUAGE FAQ

I sell FOB to an EU trader. Is CBAM my problem?▸

Legally the obligation sits with the EU importer of record. Commercially it is yours: buyers now compare offers on landed cost including CBAM, and they need your verified emissions data to avoid punitive defaults. Mills that supply clean data win the order.

What if I import less than 50 tonnes a year?▸

You are exempt under the de minimis threshold (cumulative net mass of all CBAM goods, per importer, per year). Hydrogen and electricity are excluded from the exemption. Cross the line and full obligations apply — the Commission monitors for artificial splitting.

What actually happens if we just use default values?▸

Defaults are set from the highest-emitting producers with a mark-up, so they nearly always overstate your real emissions — analyses of Q1 2026 showed default-based HRC costs up to 5× higher than verified actuals. They are a fallback, not a strategy.

Can we deduct the carbon price already paid at home?▸

Yes — a carbon price effectively paid in the country of production (net of any rebates or free allocation) reduces certificates owed. From 2027 the Commission publishes default carbon-price references per country. Keep installation-level proof of payment.

When does money actually leave our account?▸

Not before 1 February 2027. That is when certificate sales open, covering 2026 imports retroactively at each quarter’s published price. The first declaration and surrender fall due 30 September 2027; from 2027 you must also hold 50% of the year-to-date obligation at each quarter end.

Are finished steel products covered?▸

Today only the listed iron & steel goods and precursors are in scope. The December 2025 proposal extends CBAM to steel- and aluminium-intensive downstream products from 1 January 2028 — fasteners, structures, mountings and selected appliances. If you trade finished goods, start mapping metal content now.

Which side of the border are you on?

Why 2026 feels cheap — and 2034 won't

The same regulation lands differently in every country

Downstream products are next

Put a number on it