CBAM for EU Importers in 2026: The Costs Nobody Priced Into 2025 Contracts, and What to Do Before 30 September 2027

Quick answer: if you import more than 50 tonnes per year of iron and steel, cement, aluminium or fertilisers into the EU, you are in the CBAM definitive regime now. You need authorised declarant status, you owe your first annual declaration and certificate surrender by 30 September 2027 for 2026 imports, and every tonne entering on default values instead of verified supplier data is costing you the country average plus a 10% surcharge. The market's reaction so far has been avoidance: stockpiling in December, pausing in the first quarter. Avoidance has a shelf life.

How importers ended up surprised

The definitive default values landed on 31 December 2025, one day before the regime started, in annexes running past a thousand pages. EUROMETAL's president Alexander Julius described steel importers left exposed to unexpectedly high costs by last-minute rules, with none of it anticipated in contracts signed during 2025. Behaviour followed sentiment: CBAM adviser Pauline Miquel observed that many traders stockpiled in December and paused imports in the first quarter of 2026 rather than engage. Argus reported Turkish cement flows to the EU kept deliberately low on the same uncertainty.

Then, on 31 July 2026, the Commission replaced Annexes I and IV entirely, retroactive to 1 January. If your landed-cost model was built in January, it has now been wrong twice.

What you actually owe, and when

The obligations are fewer than the anxiety suggests, but each has a hard edge.

1. The 50-tonne threshold. Importers whose combined annual net mass of covered goods stays at or below 50 tonnes are exempt from authorisation, declarations and certificates. The Commission estimates this removes roughly 90% of importers while still covering about 99% of embedded emissions. Two catches: hydrogen and electricity sit outside the exemption entirely, and crossing the threshold at any point pulls your whole calendar year back into scope. Track cumulative mass, not shipment size.
2. Authorised CBAM declarant status. Above the threshold, only authorised declarants, or their indirect customs representatives acting as such, may import covered goods. Applications submitted by 31 March 2026 allowed continued importing while pending.
3. Money, later but accruing now. No certificates are bought during 2026. Sales open on 1 February 2027, priced for 2026 imports at the quarterly average of EU ETS auction prices. The first annual declaration and certificate surrender fall on 30 September 2027, covering everything imported in 2026, and every 30 September thereafter.

The gap between liability and cash is a trap of its own. Costs accrue with every 2026 import; the invoice arrives in 2027. Companies that fail to provision will meet their first CBAM bill as a lump.

The contract problem

Contracts signed in 2025 rarely say who bears the certificate cost, who supplies emissions data, or what happens when a default value changes retroactively mid-year. That silence is now a pricing dispute waiting to happen on every long-term supply agreement. Three clauses are worth negotiating into anything that renews: an explicit allocation of CBAM certificate costs, a supplier obligation to deliver installation-level emissions data verified by an accredited verifier with a deadline, and a mechanism for regulatory change, because the July correction will not be the last.

The supplier playbook before 30 September 2027

Your declaration is only as cheap as your supplier data, and since 1 January 2026 that data only counts if an accredited verifier has signed it off. The workable sequence:

1. Rank suppliers by default exposure. For each product and origin, compare the applicable default against the supplier's plausible actual intensity, times your tonnage. Miquel's advice to fertiliser importers generalises: assess the cost impact of defaults for each supplier individually and target effort where the reduction potential is biggest.
2. Push the top of the list toward verification now. Monitoring must cover the production period and verifier capacity is a bottleneck; a supplier who starts in mid-2027 will not make the deadline for 2026 data.
3. Accept defaults deliberately for the tail. For low-volume or high-intensity suppliers, defaults plus the 10% surcharge may genuinely be the rational price. The failure mode is not using defaults; it is using them by accident everywhere.

Frequently asked questions