2026 Regulation Brief

CBAM, in plain English.

Regulation (EU) 2023/956 entered its definitive period on 1 January 2026. Here's what changed for SME importers.

Threshold · 50 tonnes / year

Mandatory authorisation for importers of steel, aluminium, cement and fertilisers exceeding 50 tonnes annually. Calculated per CN-code basket per importer EORI.

Hydrogen & electricity · no threshold

From 1 kg, all imports of hydrogen and grid electricity are CBAM-scoped. There is no de minimis exemption for these categories.

Default values · 10% markup in 2026

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.

Retention · 5-year digital audit trail

All declarations, supporting evidence and supplier verification statements must be retained in machine-readable form for 5 years from the year of import.

Authorised CBAM Declarant (ACD) · Article 5

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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