CBAM for industrial importers

From 1 January 2026, CBAM is no longer just quarterly reports. The carbon border adjustment mechanism (Regulation (EU) 2023/956) has entered its definitive period: an importer of steel, aluminium, cement, fertilisers, hydrogen or electricity from outside the EU pays for the emissions embedded in the goods, through certificates. A Romanian plant that brings in bars, sheets, tubes, profiles or wire from Turkey, China, Ukraine or India is directly affected, even if it does not think of itself as an “importer” in the commercial sense and simply buys raw material.

The 2023 text was amended before the start by Regulation (EU) 2025/2083, adopted on 8 October 2025 and published on 17 October 2025, which simplified the mechanism. A second amendment, extending it to downstream products, is now under negotiation.

Which goods are covered

For a manufacturing plant two groups in Annex I of the regulation matter most:

• iron and steel: Chapter 72 of the Combined Nomenclature (with a few exceptions for ferro-alloys), plus headings 7301 to 7311, 7318 (screws, nuts, washers and similar) and 7326;
• aluminium: headings 7601, 7603 to 7614 and 7616.

The CN code in the customs declaration decides, not the commercial name. It is worth checking each imported item with your customs broker, because a welded subassembly can fall under 7308 or 7326, while a machined steel part may be outside the list.

The 50-tonne threshold

The 2025 simplification introduced a threshold by mass: an importer bringing in no more than 50 net tonnes per calendar year in total of iron and steel, aluminium, fertilisers and cement is exempt from CBAM obligations. Electricity and hydrogen do not count towards this. The exemption is declared in the customs declaration.

The trap is in going over. If you pass 50 tonnes during the year, the obligations apply to all imports of that year, not just to what exceeds the threshold. And anyone who exceeds the threshold without being an authorised declarant risks a penalty three to five times higher than the one applied to a declarant who does not surrender enough certificates. The Commission can adjust the threshold by delegated act, so the figure needs rechecking every year.

For a plant that imports a few packages of profiles a year, the threshold solves the problem. For one that brings in coils of sheet or steel bars, 50 tonnes is two or three lorries.

The authorised declarant

Above the threshold, CBAM goods can only be imported by an authorised CBAM declarant. That can be the company itself or an indirect customs representative who agrees to take on the role. Applications filed by 31 March 2026 allowed imports to continue while they were being reviewed. Anyone who did not apply by then must obtain authorisation before the first import above the threshold.

In Romania the competent authority is the Ministerul Finanțelor (the Ministry of Finance), through its CBAM and Green Taxes Directorate, according to the list published in the Official Journal of the EU on 31 July 2026. The application procedure and the documents required at national level should be checked directly with the ministry.

The annual declaration and certificates

The calendar for 2026 imports:

• the annual CBAM declaration for 2026 is due by 30 September 2027, and certificates are surrendered by the same date;
• Member States start selling certificates on the common central platform on 1 February 2027, so in 2026 there is nowhere to buy them, but the obligation builds up;
• the price for 2026 emissions is the quarterly average of EU ETS allowance prices, for the quarter in which the import took place.

So far the Commission has published 75.36 euro per tonne of CO2 for Q1, 75.28 euro for Q2 and 82.32 euro for Q3 2026. The price for Q4 is published in the first week of January 2027. From 2027 the price becomes weekly, and the declarant must hold at the end of each quarter certificates covering at least 50% of the emissions of imports since the start of the year.

The number of certificates is reduced by an adjustment reflecting the free allocation of EU ETS allowances that European producers still receive. As free allocation falls, the part paid through CBAM rises. That means the amount payable per tonne of imported steel will grow from year to year even with constant emissions and ETS price.

Default values or actual data

Embedded emissions can be calculated in two ways. The first uses the default values set by the Commission in Implementing Regulation (EU) 2025/2621, by country of origin and CN code. For steel and aluminium they include a mark-up: 10% in 2026, 20% in 2027 and 30% from 2028. The regulation must be reviewed by 2027 at the latest.

The second uses the actual emissions of the producing installation, reported by the supplier and verified by an accredited verifier. Verification is mandatory only for actual values, not for default ones.

Default values are calculated conservatively and the mark-up rises every year, so a supplier with low actual emissions has an interest in documenting them. Actual data does need the supplier’s cooperation, though: they must calculate their emissions under the EU methodology and pay for the verification.

What the plant does now

Concrete steps for procurement, together with logistics and finance:

1. From the 2026 customs declarations, extract the net mass imported under the Annex I codes and estimate the annual total. If you are close to 50 tonnes, track it monthly.
2. If you pass the threshold, check the authorised declarant status, yours or your customs broker’s, and who pays for the certificates.
3. Provision the 2026 cost in the budget: imported mass times emissions per tonne times the quarterly price, minus the free allocation adjustment. Payment comes in 2027.
4. Ask every non-EU supplier for installation-level emissions data and whether they can have it verified by an accredited verifier. A supplier who cannot answer leaves you on default values, with a rising mark-up.
5. Put clauses in contracts on supplying emissions data, the delivery deadline for it, who bears the cost of verification and what happens if the data proves wrong.
6. Compare offers on total cost: delivered price, customs duty and estimated CBAM cost. A supplier with low emissions and verified data can come out cheaper than one with a lower delivered price and no data.

What is not yet clear

On 17 December 2025 the Commission proposed extending CBAM to downstream products with a high steel and aluminium content, from 1 January 2028, plus anti-circumvention measures (COM(2025) 989). The Council set its position in June 2026 and the European Parliament in September 2026, with a longer product list than the Commission’s and a proposal to lower the threshold for aluminium. Negotiations between the institutions are only starting, so the final product list and thresholds are not known. If you import finished metal components, not just semi-finished products, follow the outcome.

The final cost of 2026 imports is only known once the Q4 price is published, in January 2027. The default values and mark-ups will be reviewed by 2027 at the latest, so the calculation for later years will have to be redone then.

If you have questions about how to build the CBAM cost into supplier offers, we talk in the WhatsApp group “Procurement & Suppliers”.