2026 Regulation Brief
Regulation (EU) 2023/956 entered its definitive period on 1 January 2026. Here's what changed for SME importers.
Mandatory authorisation for importers of steel, aluminium, cement and fertilisers exceeding 50 tonnes annually. Calculated per CN-code basket per importer EORI.
From 1 kg, all imports of hydrogen and grid electricity are CBAM-scoped. There is no de minimis exemption for these categories.
Where the importer cannot present verifier-signed supplier emissions, the EU default embedded emissions value applies — uplifted by 10% in 2026 to incentivise verified data capture.
All declarations, supporting evidence and supplier verification statements must be retained in machine-readable form for 5 years from the year of import.
Only persons holding ACD status may release CBAM goods into free circulation. Application is made to the National Competent Authority of the Member State of establishment.
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