- \n
- Problem context<\/a><\/li>\n
- Step-by-step technical analysis<\/a>\n
- \n
- CBAM is not simply a new import tariff.<\/a><\/li>\n
- Which goods are affected by CBAM?<\/a><\/li>\n
- The 50-tonne threshold: the check that must be carried out throughout the year.<\/a><\/li>\n
- Exceeding 50 tonnes does not mean paying only on the excess.<\/a><\/li>\n
- Authorised CBAM declarant: Authorisation must be obtained before importing.<\/a><\/li>\n
- The foreign supplier becomes part of CBAM compliance.<\/a><\/li>\n
- Using default values can have an economic impact.<\/a><\/li>\n
- How is the cost of CBAM certificates determined?<\/a><\/li>\n
- What happens if the product has already paid a carbon price in the country of origin?<\/a><\/li>\n
- Importing in 2026 creates an obligation even if the certificates are purchased in 2027.<\/a><\/li>\n
- Customs and CBAM are connected.<\/a><\/li>\n <\/ul>\n <\/li>\n
- Operational CBAM checklist before importing in 2026<\/a><\/li>\n\n
- Conclusion<\/a><\/li>\n<\/ol>\n\n\n\n
<\/p>\n\n\n\n
Since 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM) has entered its definitive period. We are no longer under the transitional system of quarterly reports applied between 2023 and 2025.<\/p>\n\n\n\n
Importers of certain iron and steel, aluminium, cement, fertiliser, hydrogen and electricity goods must check before importing whether their CN code is covered by CBAM, whether they can benefit from the 50-tonne exemption and, where applicable, whether they need authorised CBAM declarant status.<\/p>\n\n\n\n
The risk lies not only in the future cost of the certificates. Incorrect tariff classification, failure to monitor the cumulative volume during the year, or working with manufacturers that cannot provide reliable emissions information can affect both the cost and the very viability of the import.<\/p>\n\n\n\n
Moreover, the fact that certificates corresponding to 2026 imports will be purchased from 2027 onwards does not mean that operations carried out during 2026 fall outside the mechanism. The emissions generated now will determine the obligation that must be settled later.<\/p>\n\n\n\n
For this reason, CBAM must be reviewed before finalising the purchase with the supplier<\/strong>, not after customs clearance.<\/p>\n\n\n\n
<\/p>\n\n\n\n
Problem context<\/strong><\/h2>\n\n\n\n
<\/p>\n\n\n\n
During the transitional period, many companies viewed CBAM primarily as a reporting obligation.<\/p>\n\n\n\n
That approach is no longer valid.<\/p>\n\n\n\n
The transitional period ended on 31 December 2025 and, since 1 January 2026<\/strong>, the definitive regime provided for in Regulation (EU) 2023\/956<\/a>, subsequently amended by Regulation (EU) 2025\/2083<\/a>.<\/p>\n\n\n\n
The problem for the importer is that CBAM cannot be analysed only when the Single Administrative Document (SAD) is lodged.<\/p>\n\n\n\n
Before purchasing, the following must be known:<\/p>\n\n\n\n
- \n
- The CN code of the goods;<\/li>\n\n\n\n
- Whether that code is included in Annex I to the CBAM Regulation;<\/li>\n\n\n\n
- The annual volume the company will import;<\/li>\n\n\n\n
- Whether the 50-tonne exemption will apply;<\/li>\n\n\n\n
- Whether authorisation as a CBAM declarant is required;<\/li>\n\n\n\n
- The embedded emissions in the product;<\/li>\n\n\n\n
- The foreign manufacturer's ability to provide that information;<\/li>\n\n\n\n
- And the potential economic impact of CBAM certificates.<\/li>\n<\/ul>\n\n\n\n
A company may correctly negotiate price, transport, customs duty and VAT and yet miscalculate the true cost of the transaction because it has not factored in CBAM.<\/p>\n\n\n\n
<\/p>\n\n\n\n
Step-by-step technical analysis<\/strong><\/h2>\n\n\n\n
<\/p>\n\n\n\n
1. CBAM is not simply a new import tariff.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
CBAM is often referred to as \u201cthe carbon border tax\u201d. The expression helps explain its economic effect, but from a technical standpoint the concept should be stated more precisely.<\/p>\n\n\n\n
CBAM is a Carbon Border Adjustment Mechanism<\/strong> designed to impose on certain imported goods a carbon cost equivalent to that borne by European production under the EU Emissions Trading System \u2014EU ETS\u2014. The Regulation links the mechanism to the greenhouse gas emissions embedded during the production of the goods.<\/p>\n\n\n\n
Therefore, the CBAM cost is not determined simply by applying a percentage to the invoice value.<\/p>\n\n\n\n
The calculation takes into account the emissions embedded in the goods<\/strong> and the applicable price of CBAM certificates, together with the adjustments provided for by the rules.<\/p>\n\n\n\n
This changes the way an import is costed. The purchase price alone is no longer sufficient to determine the regulatory cost.<\/p>\n\n\n\n
![\"CBAM](\"https:\/\/www.omniaaduanas.com\/wp-content\/uploads\/2026\/08\/stacked-steel-bars-warehouse-closeup-view-industrial-materials-manufacturing-concept-574x1024.webp\")
<\/figure>\n2. Which goods are affected by CBAM?<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
CBAM currently covers specific goods in the following sectors:<\/p>\n\n\n\n
- \n
- cement;<\/li>\n\n\n\n
- iron and steel;<\/li>\n\n\n\n
- aluminium;<\/li>\n\n\n\n
- fertilisers;<\/li>\n\n\n\n
- electricity;<\/li>\n\n\n\n
- hydrogen.<\/li>\n<\/ul>\n\n\n\n
However, this list can be misleading.<\/p>\n\n\n\n
CBAM does not automatically apply to any goods containing steel or aluminium.<\/strong> The legal criterion is the CN code included in Annex I to Regulation (EU) 2023\/956<\/strong>.<\/p>\n\n\n\n
This means that the analysis must necessarily begin with tariff classification.<\/p>\n\n\n\n
And the scope is not limited to raw materials.<\/p>\n\n\n\n
For example, Annex I includes, among other goods, certain:<\/p>\n\n\n\n
- \n
- Iron or steel structures of heading 7308;<\/li>\n\n\n\n
- Screws, bolts, nuts, washers and similar articles of heading 7318;<\/li>\n\n\n\n
- Other articles of iron or steel of heading 7326;<\/li>\n\n\n\n
- Aluminium bars and profiles of heading 7604;<\/li>\n\n\n\n
- Aluminium sheets of heading 7606;<\/li>\n\n\n\n
- Aluminium structures of heading 7610;<\/li>\n\n\n\n
- Other articles of aluminium of heading 7616.<\/li>\n<\/ul>\n\n\n\n
For this reason, assuming that CBAM affects only large importers of crude steel can lead to an incorrect conclusion.<\/p>\n\n\n\n
The first check must be carried out using the product\u2019s actual CN code.<\/strong><\/p>\n\n\n\n
The official list of goods can be checked in Annex I to the CBAM Regulation<\/a> and in the information published by the Ministry for the Ecological Transition and the Demographic Challenge<\/a>.<\/p>\n<\/div><\/div>\n\n\n\n
<\/p>\n\n\n\n
3. The 50-tonne threshold: the check that must be carried out throughout the year.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
One of the main changes introduced for 2026 is the de minimis exemption based on a threshold of 50 tonnes of net mass<\/strong>.<\/p>\n\n\n\n
- \n
- The threshold is calculated: per importer + per calendar year + on a cumulative basis.<\/strong><\/li>\n<\/ul>\n\n\n\n
Each import is not assessed independently.<\/p>\n\n\n\n
- \n
- For this calculation, CBAM goods from the following sectors are aggregated: iron and steel + aluminium + fertilisers + cement.<\/strong><\/li>\n<\/ul>\n\n\n\n
Therefore, a company cannot assess each supplier, each customs declaration or each CN code in isolation. It must know its cumulative volume of CBAM goods throughout the entire calendar year.<\/p>\n\n\n\n
Imports of electricity and hydrogen cannot benefit from this 50-tonne exemption<\/strong>.<\/p>\n\n\n\n
<\/p>\n\n\n\n
4. Exceeding 50 tonnes does not mean paying only on the excess.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
This is probably one of the most important points for any importer. If, during the calendar year, the company does not exceed 50 tonnes<\/strong>, it is exempt from the CBAM obligations linked to that threshold. But if it exceeds the limit, the consequence is not limited to the tonnes above 50.<\/p>\n\n\n\n
Article 2a of the Regulation establishes that, when the threshold is exceeded, the obligations apply in respect of the emissions embedded in all CBAM goods imported during that calendar year<\/strong>. Therefore, a company should not wait until it reaches tonne 51 to assess the issue.<\/p>\n\n\n\n
If the annual forecast indicates that the threshold will be exceeded, CBAM must be planned for from the outset. The Regulation itself requires the importer to apply for authorisation when it expects to exceed<\/strong> the threshold.<\/p>\n\n\n\n
<\/p>\n\n\n\n
5. Authorised CBAM declarant: Authorisation must be obtained before importing.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
Under the definitive regime, goods subject to the mechanism may only be imported by an authorised CBAM declarant<\/strong>, unless one of the exemptions established by the Regulation applies. In Spain, the National Competent Authority for CBAM is the Ministry for the Ecological Transition and the Demographic Challenge<\/strong>, which is responsible, among other functions, for deciding on authorisation applications. Authorisation is processed through the CBAM Registry.<\/p>\n\n\n\n
For an importer established in the Union that expects to exceed the threshold, this check must be carried out before scheduling new imports that will bring it within the obligations of the mechanism<\/strong>.<\/p>\n\n\n\n
An indirect customs representative may also be involved if it agrees to act as the authorised CBAM declarant, in which case it assumes the obligations that the rules assign to the importer in respect of those goods. This point must be assessed before formalising the customs representation.<\/p>\n\n\n\n
It is not a reference that can be added to the SAD when the goods are already awaiting customs clearance.<\/p>\n\n\n\n
<\/p>\n\n\n\n
6. The foreign supplier becomes part of CBAM compliance.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
The European importer may correctly lodge a customs declaration and yet encounter a problem that originates thousands of kilometres earlier: its manufacturer does not have sufficient information on the emissions generated during production<\/strong>.<\/p>\n\n\n\n
CBAM requires the embedded emissions in the goods to be determined. From 2026, in accordance with the applicable rules, actual values or default values<\/strong> may be used. When actual emissions are used, they are subject to the verification obligations established by the Regulation.<\/p>\n\n\n\n
\nTherefore, before contracting with a supplier of CBAM goods, the following should be known:<\/p>\n\n\n\n
- \n
- Which installation produced the goods;<\/li>\n\n\n\n
- Whether it can provide the required data;<\/li>\n\n\n\n
- Which methodology it uses;<\/li>\n\n\n\n
- Whether it will be possible to substantiate the actual emissions;<\/li>\n\n\n\n
- And whether those data can subsequently be used in the CBAM declaration.<\/li>\n<\/ul>\n<\/div>
![\"Emissions](\"https:\/\/www.omniaaduanas.com\/wp-content\/uploads\/2026\/08\/smoking-factory-daytime-1024x683.webp\")
<\/figure><\/div>\n\n\n\nThis makes CBAM a supplier-selection criterion. Two manufacturers may sell exactly the same goods at the same price and generate a different CBAM impact.<\/p>\n\n\n\n
<\/p>\n\n\n\n
7. Using default values can have an economic impact.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
The rules allow default values to be used in the circumstances provided for. But those values should not automatically be regarded as a neutral solution.<\/p>\n\n\n\n
The Regulation establishes that, for goods other than electricity, default values are determined by taking as a reference the average emissions intensity of the exporting country for the relevant product and incorporating a regulatory surcharge or mark-up<\/strong>.<\/p>\n\n\n\n
Therefore, a company that is unable to obtain reliable emissions data from its manufacturer may end up relying on default values that do not necessarily reflect the actual efficiency of that installation. The issue then ceases to be purely documentary. It can become a cost issue.<\/p>\n\n\n\n
<\/p>\n\n\n\n
8. How is the cost of CBAM certificates determined?<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
Each CBAM certificate represents one tonne of CO\u2082 equivalent of embedded emissions for the purposes of the mechanism. The price is linked to the price of EU ETS emission allowances.<\/p>\n\n\n\n
For imports made during 2026<\/strong>, the Commission calculates the corresponding price using quarterly averages of EU ETS auction prices. From 2027 onwards, the calculation is performed weekly.<\/p>\n\n\n\n
Therefore, there is no fixed CBAM percentage that can simply be added to the invoice value.<\/p>\n\n\n\n
- \n
- The cost will depend, among other factors, on: quantity imported + embedded emissions + methodology used + applicable certificate price + adjustments established by the rules.<\/strong><\/li>\n<\/ul>\n\n\n\n
In addition, the number of certificates that must ultimately be surrendered will be adjusted to reflect any free allocation of allowances that still exists for equivalent production within the European Union.<\/p>\n\n\n\n
<\/p>\n\n\n\n
\n9. What happens if the product has already paid a carbon price in the country of origin?<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
The Regulation allows, under certain conditions, a carbon price that has been effectively paid in a third country<\/strong> for the declared embedded emissions to be taken into account. When the requirements are met, a reduction in the number of CBAM certificates to be surrendered may be requested. But it is not enough for the supplier to state that a carbon system exists in its country. The rules require evidence of the carbon price actually paid and consideration of any rebates, discounts or other forms of compensation available in that country.<\/p>\n\n\n\n
This documentation must be prepared at origin. Attempting to reconstruct it after the end of the calendar year can be considerably more complex.<\/p>\n\n\n\n
<\/p>\n\n\n\n
10. Importing in 2026 creates an obligation even if the certificates are purchased in 2027.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
This point can create a false sense of security. Certificates intended to cover imports made during 2026 will begin to be purchased through the common central platform from February 2027 onwards<\/strong>.<\/p>\n\n\n\n
However, the corresponding emissions are being generated by imports made since 1 January 2026.<\/p>\n\n\n\n
The first annual CBAM declaration must be submitted before 30 September 2027<\/strong>, covering imports made during 2026. The corresponding certificates must also be surrendered by that same date.<\/p>\n\n\n\n
- \n
- Therefore, not purchasing certificates during 2026 does not mean that CBAM is not generating a cost during 2026.<\/strong><\/li>\n<\/ul>\n\n\n\n
From now on, the importer must know the tonnes imported, the CN codes, the production installations and the emissions associated with the goods.<\/p>\n\n\n\n
Waiting until 2027 to reconstruct that information may leave the company dependent on incomplete data or on suppliers that are no longer available.<\/p>\n<\/div>
![\"CBAM](\"https:\/\/www.omniaaduanas.com\/wp-content\/uploads\/2026\/08\/2151989555-700x1024.webp\")
<\/figure><\/div>\n\n\n\n<\/p>\n\n\n\n
11. Customs and CBAM are connected.<\/strong><\/h3>\n\n\n\n
<\/p>\n\n\n\n
CBAM does not operate separately from the customs declaration. Customs authorities communicate to the Commission information such as the EORI number, the eight-digit CN code, the quantity, the country of origin, the date of the declaration and the customs procedure. The Commission subsequently uses this information to cross-check it against the data held in the CBAM Registry.<\/p>\n\n\n\n
This has a direct consequence:<\/p>\n\n\n\n
The tariff classification declared to Customs also determines whether a transaction may fall within the scope of CBAM.<\/strong><\/p>\n\n\n\n
Tariff classification cannot be managed separately from CBAM. They are two connected decisions.<\/p>\n\n\n\n
<\/p>\n\n\n\n
Operational CBAM checklist before importing in 2026<\/strong><\/h2>\n\n\n\n
<\/p>\n\n\n\n
Before confirming a purchase of goods potentially affected by CBAM, the importer should check:<\/p>\n\n\n\n
- \n
- Eight-digit CN code correctly determined.<\/li>\n\n\n\n
- Verification of the code in Annex I to the CBAM Regulation.<\/li>\n\n\n\n
- Country of origin not covered by an applicable exemption.<\/li>\n\n\n\n
- Cumulative CBAM net mass imported during the year.<\/li>\n\n\n\n
- Forecast of tonnes to be imported up to 31 December.<\/li>\n\n\n\n
- Determination of whether the 50-tonne exemption applies.<\/li>\n\n\n\n
- Authorisation as a CBAM declarant where required.<\/li>\n\n\n\n
- Identification of the manufacturing installation in the third country.<\/li>\n\n\n\n
- Manufacturer's ability to provide emissions information.<\/li>\n\n\n\n
- Prior determination of whether actual emissions or default values will be used.<\/li>\n\n\n\n
- Planned verification when actual values are used.<\/li>\n\n\n\n
- Analysis of any carbon price effectively paid at origin.<\/li>\n\n\n\n
- Estimate of the CBAM impact on the purchase cost.<\/li>\n\n\n\n
- Retention of the data required for the corresponding annual declaration.<\/li>\n<\/ul>\n\n\n\n
If these checks are carried out after customs clearance, the importer has already assumed part of the risk.<\/strong><\/p>\n\n\n\n
<\/p>\n\n\n\n
Conclusion<\/strong><\/h2>\n\n\n\n
<\/p>\n\n\n\n
CBAM changes the way certain imports are costed. Since 2026, it is no longer sufficient to know purchase price + transport + customs duty + VAT<\/strong>.<\/p>\n\n\n\n
For affected goods, the following must also be analysed: tariff classification + annual volume + CBAM authorisation + embedded emissions + supplier documentation capabilities + future certificate cost.<\/strong><\/p>\n\n\n\n
The new 50-tonne threshold reduces the obligations for many small importers, but at the same time creates a significant risk for companies operating close to that limit. Exceeding it during the calendar year may bring under CBAM the emissions corresponding to all affected goods imported during that year, not only the tonnes above the threshold.<\/p>\n\n\n\n
- \n
- Therefore, the correct question is not merely: \u201cDoes this import exceed 50 tonnes?\u201d<\/strong><\/li>\n\n\n\n
- The question is: \u201cWhat volume of CBAM goods will my company import over the entire calendar year, and what obligation are we creating?\u201d<\/strong><\/li>\n<\/ul>\n\n\n\n
At Omnia Aduanas, we analyse CBAM from the customs-operation perspective: CN classification, affected goods, cumulative volume, authorised declarant status and the documentation needed so that the importer understands its exposure before committing to the purchase.<\/p>\n\n\n\n
If your company imports steel, aluminium, cement, fertilisers or other goods potentially covered by CBAM<\/strong>, contact Omnia Aduanas before finalising your next transaction.<\/p>\n\n\n\n
Reviewing CBAM after importing helps identify the problem. Reviewing it beforehand makes it possible to decide whether the transaction remains viable.<\/strong><\/p>\n\n\n\n
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- The question is: \u201cWhat volume of CBAM goods will my company import over the entire calendar year, and what obligation are we creating?\u201d<\/strong><\/li>\n<\/ul>\n\n\n\n
- Therefore, the correct question is not merely: \u201cDoes this import exceed 50 tonnes?\u201d<\/strong><\/li>\n\n\n\n
- Therefore, not purchasing certificates during 2026 does not mean that CBAM is not generating a cost during 2026.<\/strong><\/li>\n<\/ul>\n\n\n\n
- The cost will depend, among other factors, on: quantity imported + embedded emissions + methodology used + applicable certificate price + adjustments established by the rules.<\/strong><\/li>\n<\/ul>\n\n\n\n
- For this calculation, CBAM goods from the following sectors are aggregated: iron and steel + aluminium + fertilisers + cement.<\/strong><\/li>\n<\/ul>\n\n\n\n
- The threshold is calculated: per importer + per calendar year + on a cumulative basis.<\/strong><\/li>\n<\/ul>\n\n\n\n
- Which goods are affected by CBAM?<\/a><\/li>\n
- Step-by-step technical analysis<\/a>\n