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    CBAMCarbon Border Adjustment Mechanism

    Definition

    Carbon Border Adjustment Mechanism — the EU framework addressing embedded emissions in specified imported goods, applying in its definitive regime from 2026.

    Editorial definition: The QHSE Standard, updated 3 October 2026 · https://qhsetech.com/glossary/cbam

    Scope: Confirm commodity coverage, thresholds, importer duties and the relevant reporting period.

    Sources checked: . Examples are editorial illustrations.

    What the CBAM definitive regime requires

    The Carbon Border Adjustment Mechanism is set up by Regulation (EU) 2023/956. The Commission describes it as the EU's tool to address carbon leakage by making the price of imports reflect their embedded carbon emissions, alongside the EU Emissions Trading System. It covers imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. A transitional phase ran from 2023 to 2025 and the definitive regime applies from 1 January 2026. The regulation defines embedded emissions as the direct emissions released during production plus the indirect emissions from electricity consumed in production, calculated by its own methods, so the terms differ from the GHG Protocol scopes.

    Regulation (EU) 2025/2083, adopted on 8 October 2025, amended the rules. An importer established in a Member State applies for authorised CBAM declarant status before importing. An importer is exempt while its cumulative net mass of imported goods in a calendar year stays within a single mass-based threshold, which the Commission page gives as 50 tonnes, and then applies only if it expects to exceed it. Once the importer exceeds it, all obligations apply to the emissions embedded in all goods it imported that year. An authorised declarant submits an annual declaration by 30 September, first in 2027 for 2026, and surrenders certificates by the same date. Member States sell certificates from 1 February 2027, priced from EU ETS auction prices as a quarterly average for 2026 and a weekly average from 2027. From 2027 the declarant must hold, at the end of each quarter, certificates for at least 50 per cent of the embedded emissions imported so far that year, measured by default values or by the previous year's surrender. Embedded emissions come from actual emissions, verified by an accredited verifier, or from default values, and a carbon price effectively paid in a third country can reduce the certificates to surrender if certified evidence is kept.

    Default values are set in Implementing Regulation (EU) 2025/2621, which the Commission page lists as corrected by Implementing Regulation (EU) 2026/1740 in an update it marks July 2026. The same page lists a proposal, COM(2025) 989, to extend scope to downstream goods and to add anti-circumvention measures. It is a proposal, so check its status before relying on it. This page is general information, not advice on an importer's duties.

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    What a CBAM record holds in software

    • The authorised declarant status and the national authority.
    • Each import line from the customs declaration: commodity code, net mass, country of origin and producing installation.
    • A running total of net mass per calendar year against the single threshold, with the date it was crossed.
    • For each installation, the operator, the verified emissions data and the verification report, or a note that default values were used.
    • Embedded emissions per good with the method (actual or default) and the boundary applied.
    • Evidence of any carbon price paid in a third country, with the certification.
    • The certificate account: purchases, quarter-end holdings, surrender and the declaration deadline.

    CBAM, the EU ETS and a Scope 3 estimate

    CBAM is not a tax on the emissions of EU producers. It prices the embedded emissions of listed imports, and its certificate price follows EU ETS auction prices. Its calculation rules and verification requirements are set by the regulation and implementing acts, so a Scope 3 estimate prepared under the GHG Protocol is not a CBAM declaration figure.

    A hypothetical example: an importer crossing the threshold

    This case is invented to illustrate the record and describes no real company. An EU importer buys iron and steel products from two suppliers. By the end of September 2026 it has imported 38 tonnes in the calendar year, and the system's running total warns it that an increase in orders would pass the single threshold. The importer applies for declarant status before further imports. By the end of the year it has imported 62 tonnes, so all 62 tonnes count, not only the 12 above the threshold.

    Supplier one has registered its installation and passes on a verified emissions figure, which the importer stores with the report. Supplier two supplies no verified data, so the importer uses default values and records that choice. For the first supplier it also holds certified evidence of a carbon price paid in the country of origin and claims the reduction. The importer plans the declaration and certificate purchases for 2027, with quarter-end holdings checked against the 50 per cent rule.

    Common misunderstandings about CBAM

    • The threshold is per importer and per calendar year, aggregated across all CN codes, not per consignment or per product, and it does not apply to electricity or hydrogen.
    • A small importer is not simply outside CBAM. An exempt importer declares the exemption in the customs declaration and must apply for declarant status if it expects to exceed the threshold.
    • The transitional quarterly reports ended with 2025. The definitive regime adds the annual declaration and certificates, with the first declaration in 2027 for 2026.
    • Default values are a fallback, not a free choice. Actual emissions must be verified by an accredited verifier where they are used.

    How CBAM relates to other glossary terms

    CBAM uses emissions data in its own regulated form, so it sits next to the GHG accounting terms without being the same.

    • Scope 1 emissions: direct emissions at an installation, which CBAM defines for the production of goods and not by ownership or control.
    • Scope 2 emissions: purchased electricity; electricity consumed in production is what CBAM calls indirect emissions, defined by its own method.
    • GHG Scope 1, 2 and 3: the corporate inventory vocabulary, which does not map one to one onto CBAM's direct and indirect emissions.
    • Scope 3 emissions: imported goods may sit in the importer's purchased-goods category, with CBAM data as one possible input.

    Records and evidence that usually exist for CBAM

    • Customs declarations and import records by commodity code, mass and origin.
    • The authorisation as declarant and registry correspondence.
    • Supplier data, verification reports and installation details.
    • Default value tables with the regulation and date used.
    • Certified evidence of a carbon price paid abroad.
    • Certificate purchase, holding and surrender records, with the declaration submitted.

    What a software tool needs to capture for CBAM

    • Import lines linked to customs data, with commodity code, mass and origin.
    • A running annual mass total against the threshold, with an alert before it is crossed.
    • Supplier and installation records with verification status and documents.
    • A switch between actual and default emissions that shows which basis each figure uses.
    • Evidence storage for third-country carbon price claims.
    • A certificate ledger with quarter-end holding checks and the 30 September deadline.

    Catalog profiles documenting CBAM compliance workflows

    Each profile documents a CBAM-related capability in its record. The list does not show that a product holds your authorisation, calculates embedded emissions to the regulation's method or connects to the registry.

    Same rule for every product: tagged “Carbon Accounting”, “Emissions Reporting”, “ESG Reporting”, “ESG Frameworks Reporting”, “Supplier Data”, “Supplier Sustainability” or “Supplier Due Diligence”, with a sourced CBAM capability in its record, or one the vendor stated to us, labelled as vendor-stated. Documented and conditional capabilities qualify; check the linked scope before treating a module as included.

    Tekmon pays for a sponsored placement (above); its place in this list follows the same rule as every entry. How lists are ordered

    All 2 matching profiles are shown. Documentation review, not hands-on testing or a claim of compliance.

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    Frequently asked questions

    Does CBAM apply to a small importer?

    An importer whose cumulative net mass of covered goods stays within the single threshold in a calendar year is exempt, and the Commission page gives the threshold as 50 tonnes. The importer declares the exemption in its customs declaration and applies for declarant status if it expects to exceed the threshold.

    When is the first CBAM declaration due?

    Regulation (EU) 2023/956 as amended requires the declaration by 30 September each year, for the first time in 2027 for 2026, with certificates surrendered by the same date. Member States sell certificates from 1 February 2027.

    Can default values be used instead of supplier data?

    The regulation allows embedded emissions to be determined from default values or from actual emissions, and actual emissions must be verified by an accredited verifier. The default values are set in Implementing Regulation (EU) 2025/2621 as corrected, so check the version.

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