CBAM for importers of steel and aluminium

The Carbon Border Adjustment Mechanism, CBAM, has applied in its definitive form since 1 January 2026, according to the European Commission. It covers imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. An importer bringing in more than 50 tonnes a year of CBAM goods in the first four sectors, or any electricity or hydrogen, must hold the status of authorised CBAM declarant. Certificates for 2026 imports go on sale in February 2027, and the first annual declaration is due by 30 September 2027.

For manufacturers outside the EU, the most important point is structural. A company not established in the EU cannot import CBAM goods itself. It goes through an indirect customs representative, which must take on the CBAM obligations.

Which goods fall under CBAM?

The Commission lists six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The goods themselves are listed by Combined Nomenclature code in Annex I to Regulation (EU) 2023/956, the CBAM Regulation, as Germany’s CBAM authority, DEHSt, explains.

Coverage follows the tariff code. A product counts as a CBAM good because its code is listed in Annex I, not because it contains steel or aluminium somewhere inside. A finished machine made partly of steel falls outside CBAM unless its own code appears in the annex. Aluminium profiles or steel products whose codes are listed fall inside it.

The first step for any importer is therefore a list of the codes it imports, checked line by line against Annex I. HS codes and Binding Tariff Information explains how those codes are set.

What is the CBAM 50-tonne threshold?

Regulation (EU) 2025/2083, adopted on 8 October 2025 and published in the Official Journal on 17 October 2025, simplified CBAM before the definitive period. Its main change is a single mass-based threshold.

DEHSt sets out how it works:

• The threshold is met where the “cumulative net mass of imported CBAM goods in the cement, iron and steel, fertilisers and aluminium sectors” does not exceed 50 tonnes in a given calendar year.
• The mass is aggregated per importer and per calendar year, across all CN codes in Annex I.
• The threshold “does not apply to the CBAM goods hydrogen and electricity.”

An importer below 50 tonnes a year in those four sectors is outside the CBAM obligations. One above it needs authorisation before importing the goods that take it over the line. Because the count runs across the year, a mid-year contract can change an importer’s position.

Who can be an authorised CBAM declarant?

DEHSt states the rule plainly: “Before importing electricity or hydrogen or more than 50 tonnes of other CBAM goods, you must obtain the status of an approved CBAM declarant.” The application goes to the national competent authority, and in Germany that authority is DEHSt itself.

There was a transitional easement for the start of the definitive period. Importers that applied for authorisation by 31 March 2026 may provisionally import CBAM goods above the threshold until a decision is taken on their application. An importer applying now does not have that easement and needs its status in place first.

Importing without authorisation carries consequences. DEHSt points to import restrictions and penalty procedures under Articles 25a and 26 of the CBAM Regulation.

Can a company outside the EU import CBAM goods?

Not directly. DEHSt explains that importers not established in an EU member state “can only import CBAM goods via an indirect customs representative.” For those importers, the indirect customs representative “must assume these CBAM obligations in respect of the importer’s CBAM goods,” under Article 5(2) of the CBAM Regulation. The representative must itself hold authorised declarant status.

For EU-established importers the position differs. An indirect customs representative may take on the obligations, under Article 5(1a), but is not required to.

For a manufacturer outside the EU with CBAM goods above the threshold, the practical question comes early. Which authorised indirect customs representative will take on its CBAM obligations, and on what terms? That arrangement needs to exist before the goods ship.

When are CBAM certificates bought and surrendered?

Step	Timing	Source
Definitive regime applies	From 1 January 2026	European Commission
Certificates for 2026 imports on sale	From February 2027, on a central platform through the CBAM registry	DEHSt
First annual CBAM declaration	By 30 September 2027, for 2026	DEHSt
Surrender of certificates	By 30 September of each year	DEHSt
Price basis for 2026	Quarterly average of EU ETS allowance auction prices	European Commission

Authorised declarants buy certificates from the national competent authority in their member state, according to the Commission. Certificates covering 2026 imports are therefore bought in 2027, but the quantity needed follows the emissions embedded in the goods imported in 2026. An importer budgeting for this year’s volumes needs an estimate of embedded emissions now.

A worked example

Suppose a manufacturer of industrial equipment outside the EU ships two product lines to Portugal: aluminium profiles sold to EU fabricators, and finished machines. The details are hypothetical, for the mechanics only.

Its broker confirms that the profiles’ code is listed in Annex I and the machines’ code is not. Only the profiles count towards the threshold.

In the first half of the year, it imports 30 tonnes of profiles. A new contract in July adds 40 tonnes for delivery in the autumn. The annual total would reach 70 tonnes, above the 50-tonne threshold.

Because the manufacturer is not established in the EU, it cannot become an authorised declarant itself. It agrees terms with an indirect customs representative that holds authorised status and will assume its CBAM obligations. The July contract ships only once that arrangement is in place.

The manufacturer also asks its producing plant for the emissions data behind the profiles. Its representative will need that data for the declaration due by 30 September of the following year.

This is general information, not legal or customs advice. CBAM obligations for specific goods are confirmed with a customs adviser and the competent authority.

How does EFC treat CBAM goods?

EFC does not act as CBAM declarant for clients and does not take on CBAM obligations. For goods that fall under CBAM, the authorised declarant arrangement is the client’s to settle, with its customs representative, before the goods leave the factory. EFC’s part begins after import: storage, finishing and dispatch at its base in Portugal, run with its logistics partner, as outlined on industrial. Goods usually enter through release for free circulation, and EFC does not classify goods or determine which codes fall under Annex I.

Sources

Label	Value	Source
CBAM definitive regime	applies from 1 January 2026; sectors: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen	European Commission, Carbon Border Adjustment Mechanism, opened 2026-09-02
Certificates	bought from the national competent authority; 2026 price as a quarterly average of EU ETS auction prices	European Commission, CBAM definitive regime, opened 2026-09-02
Threshold, authorisation, dates	50 tonnes per importer per calendar year in four sectors; not for hydrogen and electricity; applications by 31 March 2026; certificates from February 2027; declaration by 30 September 2027 for 2026; surrender by 30 September; third-country importers via an indirect customs representative; Articles 5(2), 25a and 26	DEHSt, CBAM definitive regime from 2026, opened 2026-09-02
Regulation (EU) 2025/2083	adopted 8 October 2025; published 17 October 2025; single 50-tonne threshold; electricity and hydrogen importers not exempt	CMS Portugal, amendment to Regulation (EU) 2023/956, opened 2026-09-02