EU trade · last verified 2026-09-14
EU CBAM is a product log, not a company footprint
The definitive regime applies from 1 January 2026. The person who imports covered goods into the Union — or their indirect customs representative — keeps the record.
Covered goods
Cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen. If you do not import those into the EU, CBAM is not your corporate reporting duty. A customer that imports them may still ask you, as a non-EU installation operator, for installation data through the CBAM Registry.
The 50-tonne screen
Importers who bring in more than a single mass-based threshold of 50 tonnes of CBAM goods generally must apply for authorised CBAM declarant status. Electricity and hydrogen are covered sectors but do not always map onto that goods-mass test; the checker marks those flows as monitor instead of pretending the 50-tonne rule is universal.
What they log
- Embedded emissions of the imported goods (actual verified data, or defaults that carry a mark-up).
- Production route, precursors, and installation identity where required.
- Carbon price already paid at origin, if you will deduct it.
- Certificate holdings. Sales begin February 2027. The first annual declaration covering 2026 imports is due 30 September 2027.
Commission guidance is explicit: CBAM embedded emissions start at the installation and are attributed to goods. That is not a GHG Protocol corporate inventory and not a full life-cycle product footprint.