CBAM was introduced in two stages. The transitional period ran from October 1, 2023, to December 31, 2025, and required only reporting on embedded emissions. The definitive period began on January 1, 2026, and brought a financial obligation: buying and surrendering CBAM certificates.
Transitional period: October 1, 2023 – December 31, 2025
During the transitional period, importers of CBAM goods reported the embedded emissions of the goods they brought in but did not pay for them. The point of this stage was to give supply chain participants time to set up data collection and to let the regulator refine its methods.
For producers outside the EU, this period was their first real experience: European buyers began asking for installation-level data, specific emissions per tonne of product and information on precursors. What this data includes is explained in CBAM goods and embedded emissions.
Definitive period: from January 1, 2026
From the beginning of 2026, the rules changed:
- Authorized declarant. CBAM goods above the threshold may be imported only by an authorized CBAM declarant.
- 50-tonne threshold. The simplification Regulation (EU) 2025/2083 set a single threshold of 50 tonnes of goods per importer per year, by mass. Importers below the threshold are exempt from CBAM obligations.
- CBAM certificates. Embedded emissions are covered by certificates that the declarant buys and surrenders.
- Carbon price paid. The number of certificates is reduced by the carbon price actually paid in the country of production; see CBAM and the carbon price.
Key dates for 2026 imports
| Event | Deadline |
|---|---|
| Start of the definitive period | January 1, 2026 |
| Start of CBAM certificate sales for 2026 imports | February 1, 2027 |
| First annual declaration and certificate surrender | By September 30, 2027 |
In other words, emissions data for goods imported in 2026 has to be collected in advance: the declarant relies on it to prepare the first annual declaration.
Gradual phase-in of the obligation
The definitive period does not mean that the importer immediately pays for all embedded emissions. Free EU ETS allowances for CBAM sectors are being phased out gradually, and the share of emissions covered by CBAM certificates is growing in step. For the specific schedule, see regulatory documents.
What this means for suppliers
For a producer outside the EU, the change of period marks a shift from “reporting for the sake of reporting” to data that the buyer's money depends on:
- Actual installation data reduces the risk of conservative default values being applied.
- The buyer will need data for 2026 for its first annual declaration in 2027.
- The 50-tonne threshold applies to the importer: if your buyer is below it, you may get no requests, but large buyers will send them.
For a practical list of the data, see CBAM for exporters.
How it works in the platform
- The CBAM contour is still in development and marked “Soon”.
- An installation's energy and fuel are recorded in Data entry: for each facility, for completed years, month by month and with supporting documents. This means 2026 can be entered as soon as the year is over, so collect invoices, certificates of completion and meter readings for every month in advance.
- After the completeness check, the facility's year is closed; a closed year backed by documents is a reliable basis for the data your buyer will ask for.
Frequently asked questions
Do we need to do anything with data from the transitional period?
There is no obligation to pay for imports made during the transitional period. Still, the data you have accumulated is useful: it shows how to calculate the installation's emissions and helps you align your approach with the buyer.
What happens to an importer below the 50-tonne threshold?
Under Regulation (EU) 2025/2083, importers bringing in less than 50 tonnes of CBAM goods per year are exempt from CBAM obligations.
When is payment due for 2026 imports?
Certificates for 2026 imports go on sale on February 1, 2027; they must be surrendered together with the first annual declaration by September 30, 2027.