CBAM's first bill arrives in 2027: what changed in 2026

After a two-year transitional period in which importers only reported emissions, the EU Carbon Border Adjustment Mechanism became a financial obligation on 1 January 2026. Here is what changed this year, and what it means for exporters of steel, aluminium, cement, fertilisers and hydrogen to the EU.

The timeline, simplified

The 50-tonne threshold

The Omnibus simplification replaced the old €150-per-consignment exemption with a cumulative annual threshold of 50 tonnes per importer across iron and steel, aluminium, fertilisers and cement. It does not apply to electricity or hydrogen. According to the Commission's own estimate, reported widely, this exempts about 90% of importers, mostly small businesses and individuals, while keeping about 99% of embedded emissions covered. The threshold is all-or-nothing: once an importer passes 50 tonnes in a year, obligations apply to all of that year's imports.

For Indian exporters the practical effect is small. Industrial buyers of steel and aluminium import well above 50 tonnes, so they remain fully in scope.

The first prices

For 2026 imports the certificate price is the quarterly volume-weighted average of EU ETS auction prices. The Commission published €75.36 per tonne for Q1 2026 on 7 April and €75.28 for Q2 on 6 July. From 2027 the price will be published weekly.

Corrected default values

Implementing Regulation (EU) 2026/1740, published on 31 July 2026, replaced the annexes of country and product default values set in 2025/2621 and applies retroactively from 1 January 2026. Most changes are small, but some are large enough to affect sourcing decisions. The corrected annex also drops the precomputed yearly columns: the CBAM Registry now applies the mark-up (10% in 2026, 20% in 2027, 30% from 2028) to the total. Some goods are now identified by ten-digit TARIC codes where the eight-digit CN code is too broad.

The downstream extension

On 17 December 2025 the Commission proposed extending CBAM from 1 January 2028 to about 180 downstream products with high steel or aluminium content. It reports that 94% of them are intermediate industrial goods such as fittings, cylinders, radiators and machinery parts. The proposal would also count pre-consumer steel and aluminium scrap as a precursor, to close a circumvention route. It still has to pass the ordinary legislative procedure, so treat the scope and date as proposed, not final.

What to do now

• Ask your EU customers whether they will declare actual emissions or defaults for your products, and when they need your data.
• Start collecting installation-level fuel, electricity and precursor data for 2026. The first declaration covers the full calendar year.
• Run your products against the corrected default values to see what your buyer pays if you supply nothing.
• If you make downstream steel or aluminium goods, map your CN codes against the proposed extension list.