Does your company need CBAM documentation?
4 questions. 30 seconds. Find out if Regulation (EU) 2023/956 applies to your imports.
Regulation (EU) 2023/956 — In force since 1 January 2026
Question 1 of 4
Does your company import goods into the EU from non-EU countries?
CBAM applies to anyone who introduces goods into the customs territory of the EU (Art. 2(1) of Regulation (EU) 2023/956). This also applies if you use an indirect customs representative.
Question 2 of 4
Which sector do your imported goods belong to?
CBAM covers exclusively the 6 sectors listed in Annex I of Regulation (EU) 2023/956. If your goods are not in any of these sectors, they are not subject to CBAM.
Question 3 of 4
Do you import more than 50 net tonnes per year of CBAM goods?
Art. 2a of Regulation (EU) 2023/956 establishes a de minimis threshold of 50 net tonnes per year. Below that threshold, CBAM declarant authorisation is not required. However: if you exceed the threshold during the year, you become retroactively subject to all obligations (Art. 2a(2)).
Question 4 of 4
Do you already have CBAM declarant authorisation?
Art. 5 of Regulation (EU) 2023/956 requires every importer of CBAM goods to apply for authorisation with the competent authority of their Member State. Without authorisation, you cannot clear CBAM goods through EU customs.
Your company is within the scope of CBAM.
Your imports are subject to Regulation (EU) 2023/956. You need to prepare your CBAM documentation before the first annual declaration deadline of 30 September 2027.
What you need to do
- Apply for CBAM declarant authorisation (Art. 5) if you don't have it
- Calculate the embedded emissions of your imports (Art. 7 + Annex IV)
- Estimate how many CBAM certificates you need to purchase (Art. 22)
- Document the carbon price paid in the country of origin (Art. 9)
- Organise record-keeping for 4 years (Annex V)
- Prepare communication with your foreign suppliers (Art. 10)
See what the CBAMCheck dossier includes
Your imports are not subject to CBAM.
CBAM only applies to the 6 sectors listed in Annex I of Regulation (EU) 2023/956: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. If your goods do not belong to any of these sectors, you do not need CBAM documentation.
Could this change?
- The European Commission may expand the list of sectors in the future
- If you start importing goods from the covered sectors, CBAM will apply
- Other regulations may affect your imports (GPSR, CRA, EUDR...)
CBAM does not apply to intra-EU purchases.
The Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) only applies to goods imported from outside the European Union. Purchases between EU Member States are not subject to CBAM, as EU producers already pay for their emissions through the EU ETS.
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Caution: you could become subject to CBAM retroactively.
Even if you import less than 50 tonnes now, Art. 2a(2) of Regulation (EU) 2023/956 states that if you exceed the threshold during the year, you become retroactively subject to all obligations. If you are close to the limit, preparing the documentation is advisable.
Our recommendation
- Monitor your CBAM import volume month by month
- Prepare documentation preventively if you expect to approach 50 t
- If you exceed the threshold, you will need declarant authorisation and certificate purchase
See what the CBAMCheck dossier includes