Legislation and regulation
Paula Otero
Environmental and Sustainability Consultant

If you import iron and steel, cement, aluminium, fertilisers, electricity or hydrogen, four dates govern your calendar: since 1 January 2026 only an authorised CBAM declarant may import CBAM goods; on 1 February 2027 sales of certificates begin on the EU central platform; the first annual declaration, covering 2026 imports, is due by 30 September 2027; and the corresponding certificates are surrendered on that same date.
The declaration deadline moved: Regulation (EU) 2025/2083 of 8 October 2025 shifted it from 31 May to 30 September. If your internal plan still points at May, it is out of date.
This is the entry condition. Since 1 January 2026, only an authorised CBAM declarant, either the importer or its indirect customs representative, may bring goods covered by the mechanism into the Union. It is not a follow-up formality, it is a prerequisite to clearance.
If you have not applied yet and expect to cross the threshold, the right order is to apply before committing the next order, not after.
Regulation (EU) 2025/2083 replaced the old €150 per consignment threshold with a far more workable mass threshold: 50 tonnes of net mass per year, per importer, aggregated across all Annex I goods.
Three points that cost money when overlooked:
If you are anywhere near the limit, run a cumulative net-mass counter per EORI, with an alert from 40 tonnes.
| Date | What happens |
|---|---|
| 1 January 2026 | The definitive regime starts. Only authorised declarants may import. The transitional period and its quarterly reports end |
| 31 March 2026 | Last day to have filed the authorisation application and still import above the threshold while it is decided |
| 7 April 2026 | The Commission publishes the first quarter 2026 price: €75.36 per certificate |
| 6 July 2026 | Second quarter 2026 price: €75.28 |
| 5 October 2026 | Publication of the third quarter 2026 price |
| 31 December 2026 | End of the first calendar year of the definitive regime. Net mass imported is fixed, and with it whether you passed the de minimis |
| 4 January 2027 | Publication of the fourth quarter 2026 price |
| 1 February 2027 | Sales of CBAM certificates open on the central platform, covering emissions in goods imported during 2026 |
| During 2027 | The price moves to weekly calculation and publication |
| 30 September 2027 | First annual CBAM declaration, covering 2026, and surrender of the corresponding certificates |
Certificates are sold through a common central platform, not on a secondary market. What matters about the price:
Regulation (EU) 2025/2083 also cut the quarterly holding requirement: an authorised declarant must hold in its account, at the end of each quarter, certificates covering at least 50% of the embedded emissions in goods imported since the start of the calendar year. It used to be 80%. Less pressure on cash, but it still needs planning: buy everything in September and you pay September's price.
The declaration sets out, for each type of good, the total quantity imported in the previous calendar year, in tonnes and, for electricity, in megawatt hours. Alongside that:
Default values are an alternative, but calculating with verified actual emissions usually works out better when the source installation is efficient. That is an economic decision and it should be made with numbers, not out of convenience.
This is the slowest piece of work and the one almost nobody starts early enough. Ask in writing, and per production installation rather than per supplier:
A supplier that has never done this takes months to produce it. Put it in the purchase terms rather than in a last-minute email. If you sell into the EU from outside, the exporter's angle is covered in the article on CBAM 2026 for Mexican exporters, and how the mechanism works overall is in the CBAM 2026 guide.
Fewer than four months remain to close the first calendar year of the definitive regime. What should be settled before 31 December:
If you also manufacture or process inside the EU, much of the per-installation data CBAM demands is the same data you need for your own product carbon footprint in an industrial company. Worth building once, using the method set out in the guide to what a product carbon footprint is and how it is measured.
By 30 September 2027, covering imports made in calendar year 2026. Regulation (EU) 2025/2083 moved the deadline from 31 May to 30 September.
No. Sales on the central platform start on 1 February 2027 and cover emissions in goods imported during 2026.
Per importer and year, aggregating all Annex I goods. Electricity and hydrogen sit outside the threshold and always trigger the obligation.
The obligation covers the whole calendar year, with no retroactive exemption for earlier imports. That is why it pays to be authorised before crossing it.
As the weighted average of the auction clearing prices of auctioned EU ETS allowances. In 2026 it is published quarterly; from 2027, weekly.
Yes, but they tend to be conservative. If your supplier is efficient, declaring verified actual emissions reduces the number of certificates to surrender.
Preparing for CBAM and calculating your product carbon footprints is, at bottom, the same data exercise per installation and per unit produced. Our product carbon footprint solution organises that information so the annual declaration comes out of data you already hold.
Paula Otero
Environmental and Sustainability Consultant
About the author
Biologist from the University of Santiago de Compostela with a Master’s degree in Natural Environment Management and Conservation from the University of Cádiz. After collaborating in university studies and working as an environmental consultant, I now apply my expertise at Manglai. I specialize in leading sustainability projects focused on the Sustainable Development Goals for companies. I advise clients on carbon footprint measurement and reduction, contribute to the development of our platform, and conduct internal training. My experience combines scientific rigor with practical applicability in the business sector.
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