The Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026, ending the reporting-only transitional phase that ran since October 2023. Imports of cement, iron and steel, aluminium, fertilisers, hydrogen and electricity into the EU are now subject to the full machinery — and mid-2026 is the moment its practical consequences are landing on importers.
Authorisation is no longer optional
Since 1 January, CBAM goods above the threshold may only be released for free circulation by an authorised CBAM declarant, evidenced by TARIC document codes on the customs declaration itself. Importers who filed their application by the 31 March 2026 deadline may continue importing provisionally while their decision is pending — but those who missed it face goods blocked at the border and penalties of three to five times the standard €100-per-tonne rate for unauthorised imports. The authorisation status has become as fundamental to these commodity flows as the EORI number.
The 50-tonne threshold — relief with a retroactive sting
The Omnibus simplification (Regulation (EU) 2025/2083) replaced the old €150-per-consignment relief with a single mass-based threshold: importers bringing in 50 tonnes or less of covered goods per calendar year (hydrogen and electricity excluded) fall outside CBAM entirely. The Commission estimates this exempts around 90% of importers while keeping 99% of embedded emissions in scope. The sting is in the mechanics: cross the threshold mid-year and CBAM obligations apply retroactively to every tonne imported since January — so businesses hovering near 50 tonnes need live volume tracking, not a year-end reconciliation.
One detail matters enormously for non-EU businesses: indirect customs representatives require authorisation with no threshold at all whenever they declare CBAM goods on an importer's behalf. Choosing a representative that holds CBAM authorisation is now part of choosing an import partner.
The money arrives in February 2027
Certificate sales open on the Common Central Platform on 1 February 2027 — but they cover 2026 imports retroactively. Prices track EU ETS auction averages, set quarterly for 2026 (the Commission published Q1 2026 at €75.36 per tonne of CO₂e) and weekly from 2027. The first annual declaration and certificate surrender for 2026 imports falls due by 30 September 2027, with a rolling requirement from 2027 to hold certificates covering at least 50% of year-to-date embedded emissions each quarter. Importers using default emission values should note they carry deliberate mark-ups — verified actual supplier data is usually the cheaper route, and building that data pipeline takes months, not weeks.
And the scope is growing
The Council has agreed to extend CBAM to a range of downstream steel and aluminium goods — screws, structures and processed articles — alongside reinforced anti-circumvention rules, closing the loophole where processing a covered material one step further escaped the mechanism. Businesses importing metal-intensive products that are outside CBAM today should assume they will not stay outside it.
The mid-year action list
- Verify authorisation status — yours, or your indirect representative's — before the next consignment, not after it is held.
- Track tonnage against the 50-tonne threshold in real time, remembering obligations bite retroactively.
- Start the supplier-data pipeline now so 2026 declarations can use verified actual emissions instead of marked-up defaults.
- Budget for certificates at quarterly-average ETS prices against 2026 import volumes — the cash leaves in 2027, but it is a 2026 cost.
flexfrontier acts as importer and indirect customs representative for CBAM-covered flows, files the declarations with the correct CBAM codes, and coordinates the authorisation and data groundwork the September 2027 deadline depends on. If your goods contain steel, aluminium, cement or fertilisers, now is the checkpoint.