CBAM: the 50-tonne threshold, certificates from 2027 and what importers do now

What is CBAM?

CBAM (Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956) is the EU levy on the carbon content of certain imported goods. Anyone importing iron and steel, aluminium, cement, fertilisers, electricity or hydrogen from non-EU countries has had to record the embedded emissions since 1 January 2026 and, from 2027, buy CBAM certificates at the EU ETS price. The aim is that imported steel carries the same carbon price as steel produced in the EU.

Core rule, in substance from Articles 1 and 22 of the regulation: the authorised CBAM declarant submits a CBAM declaration for the previous year by 30 September each year and surrenders the number of certificates corresponding to the declared embedded emissions. The certificate price is the average of ETS auction prices, calculated weekly or quarterly.

Who is affected?

Every company that imports CBAM goods listed in Annex I into the EU, provided it exceeds the de minimis threshold:

• Goods: iron and steel (including screws, nuts, pipes, sheets, many semi-finished products), aluminium (profiles, sheets, foil), cement, fertilisers, hydrogen, electricity.
• Threshold: anyone importing less than 50 tonnes of these goods per calendar year (net mass, cumulated across all shipments) is exempt. Electricity and hydrogen do not count towards the threshold and always remain in scope. According to the Commission, the threshold exempts around 90 % of previous importers while keeping over 99 % of emissions covered.
• Authorised CBAM declarant: anyone above the threshold has needed authorised declarant status since 2026. Without authorisation the goods may not be imported.

Not affected: companies that only buy CBAM goods within the EU. The steel trader in Duisburg selling you imported steel is the importer, not you. Finished machines and equipment containing steel are also out of scope as long as their customs tariff code is not in Annex I. And anyone staying below 50 tonnes has nothing to declare, but should be able to prove the quantities.

What applies from when?

Which concrete obligations arise?

1. Apply for authorisation: authorised CBAM declarant status in the CBAM registry (in Germany via the DEHSt as competent authority). No authorisation, no imports above the threshold.
2. Record emissions data per supplier and installation: direct and, for some goods, indirect emissions per tonne, following the methodology of the implementing regulation. The data comes from the manufacturer in the third country, not from the freight forwarder.
3. Use default values if no data is available: the Commission publishes default values per country and product. They include a mark-up of 10 % (2026), 20 % (2027) and 30 % (from 2028); 1 % per year for fertilisers. Default values are deliberately set so that real data is cheaper.
4. Buy and hold certificates: from 1 February 2027 via the national platform; from 2027, cover at least 50 % of accumulated emissions at the end of each quarter.
5. Submit the annual CBAM declaration: by 30 September for the previous year, with quantities, emissions, carbon price paid in the country of origin (creditable) and verification by accredited verifiers where required.
6. Retain records: emissions reports, supplier evidence and calculations for authority checks.

Common misconceptions

• Calculating the threshold per shipment. The 50 tonnes are cumulated per calendar year and importer. Exceed it in November and you are liable for the whole year, including January imports.
• Only looking at raw steel. Annex I contains many processed goods: screws, nuts, wire rope, containers, pipes, aluminium profiles. The customs tariff code decides, not the material name.
• Treating default values as the easy route. The mark-ups rise to 30 % by 2028. With 500 tonnes of steel at roughly two tonnes of CO₂ per tonne and a certificate price around 75 €, that quickly adds up to five-figure extra costs per year.
• Requesting emissions data only in the declaration year. Installations in third countries need months to produce reliable data. Collect nothing in 2026 and you will declare with a mark-up in 2027.

How SCRM Guard helps

The CBAM compliance module on the platform maps your imported commodity groups to CBAM tariff codes, checks annual quantities against the 50 t threshold and shows whether you are in scope. For in-scope commodity groups, the platform requests emissions data from suppliers and their installations in a structured way, follows up automatically and documents which values are verified and where default values still apply. So you see what the missing data costs before you declare.

In the full service we run the entire data chain to your suppliers: request, plausibility check, follow-up, preparation for the CBAM declaration. And if you are below the threshold, we tell you that too, with the quantity evidence the authority wants to see.

Sources

• Regulation (EU) 2023/956 (CBAM), EUR-Lex (16 May 2023)
• Regulation (EU) 2025/2083 simplifying the CBAM (50 t threshold) (17 Oct 2025)
• Implementing Regulation (EU) 2025/2621 (default values and mark-ups) (19 Dec 2025)
• German Emissions Trading Authority (DEHSt): CBAM certificates and prices (06 Jul 2026)
• European Commission: CBAM overview (Taxation and Customs Union) (01 Jan 2026)

This page is an editorial briefing for procurement and compliance teams in mid-sized companies, not legal advice. We check deadlines and thresholds against primary sources; the review date is shown at the top of the page.