New CBAM Guidance Sets Out Key Requirements for Importers

The European Commission has updated its guidance on the Carbon Border Adjustment Mechanism (CBAM) , setting out compliance obligations for importers ahead of the regulation’s definitive phase.

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Under the revised framework, importers of CBAM-covered goods entering the EU must obtain authorised declarant status as of 1 January 2026. A 50-tonne annual import threshold applies to most goods in scope. Hydrogen and electricity imports fall outside this threshold.

The 2026 reporting year will be the first subject to CBAM’s full declaration requirements. Submissions will be due by 30 September 2027. CBAM certificates—required to account for the embedded carbon emissions of covered goods—will be purchasable from 1 February 2027. A quarterly minimum holding requirement for certificates will come into effect from the same year.

The updated guidance gives increased weight to the use of verified emissions data at the installation level, in line with the EU’s focus on production conditions of imported goods. Default values remain available to importers unable to obtain verified data. The Commission has noted, however, that these defaults incorporate mark-ups and carry a higher cost burden than verified alternatives.

Legal accountability for the accuracy of CBAM declarations rests with the authorised declarant, irrespective of whether the underlying emissions data originates from the declarant, their suppliers, or external parties.

The guidance forms part of the EU’s broader effort to prepare industries for full CBAM operation. The mechanism aims to align the carbon cost of imported goods with that of EU-produced equivalents, in support of the bloc’s domestic carbon pricing objectives.