CBAM FAQ: prices, the 50-tonne rule, and the phase-in

On 1 January 2026. The European Commission’s definitive-regime page and Regulation (EU) 2023/956 both date it then.

Yes if you import more than 50 tonnes of CBAM goods in a calendar year, counting iron and steel, aluminium, cement and fertilisers together. Hydrogen and electricity always need authorised declarant status, at any quantity. If the importer is not established in the EU, the indirect customs representative needs the status even below 50 tonnes.

The exemption applies when the net mass does not exceed 50 tonnes. Fifty tonnes does not exceed 50 tonnes. The moment the year goes over 50, the obligations apply to all of that year’s imports of those goods, not only the excess.

For 2026 the Commission has published three quarterly prices: €75.36 (7 April 2026), €75.28 (6 July 2026) and €82.32 (5 October 2026). The Q4 price is due on 4 January 2027 and was not published when we checked on 31 October 2026. Each quarterly price applies to goods imported in that quarter.

Implementing Regulation (EU) 2025/2548 sets it as the average of EU ETS auction clearing prices, weighted by the volume sold at each auction. Cancelled auctions are left out. In 2026 that average is quarterly. From 2027 it is weekly.

Sales on the common central platform start on 1 February 2027. Certificates for 2026 emissions are bought from that date and surrendered by 30 September 2027. From 2027 you also have to hold, at each quarter-end, certificates for at least 50% of year-to-date embedded emissions, after the free-allocation adjustment.

By 30 September of the following year. The first deadline is 30 September 2027, for 2026. Surrender of the certificates is due the same day.

The CBAM factor in Directive 2003/87/EC Article 10a(1a) is 97.5% in 2026, so a simplified reading charges 2.5% of embedded emissions. The factor then falls each year. From 2034 no CBAM factor applies, and Commission guidance lists it as 0%, which on that same simplified reading means 100% is paid. The legal surrender uses a benchmark adjustment under Implementing Regulation 2025/2620, and electricity’s adjustment is zero.

Annex I covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, by CN code, with exceptions such as certain ferro-alloys and ferrous scrap. Iron and steel, aluminium, hydrogen and electricity count direct emissions only.

Yes, within Article 9. The price has to have been effectively paid, rebates and similar compensation come off the claim, and actual emissions need the evidence the article describes. If default emission values are used, the reduction uses yearly default carbon prices instead. The deduction is a reduction in certificates, not a casual discount.