CBAM • Carbon border adjustment • Import • Compliance • EU ETS
CBAM: the carbon border adjustment that affects imports of steel, aluminium and more
CBAM affects importers ever more directly. Since 1 January 2026 the definitive phase of this European carbon border mechanism has been running: anyone importing carbon-intensive goods such as steel or aluminium needs an authorisation and will pay for the CO₂ released during production. Without compliance, Customs holds shipments at the border. Good news for smaller importers: below 50 tonnes a year you are now exempt.
In short: what is CBAM?
CBAM (Carbon Border Adjustment Mechanism) is the European Union's carbon border correction mechanism. Importers of iron and steel, cement, fertilisers, aluminium, electricity and hydrogen pay a CO₂ price on the emissions released during production outside the EU, comparable to what EU producers pay under the emissions trading system. Since 1 January 2026 the definitive phase applies, with an exemption for importers up to 50 tonnes of CBAM goods per year.
CBAM runs entirely through the import process and therefore directly touches customs matters, import and sea freight. Just like the EORI number and the EUDR, CBAM is now part of the standard preparation of shipments containing risk goods.
Why CBAM can no longer be ignored
The core of CBAM is a level playing field: products from outside the EU will carry the same CO₂ costs as products made within the EU under the emissions trading system. That is why, as an importer, you pay a CO₂ correction if you import more than 50 tonnes of CBAM goods per year — via certificates whose price is linked to the price in the European emissions trading system.
Enforcement is built directly into the import process. Anyone wanting to import CBAM goods above the threshold must be authorised in advance as a CBAM declarant by the Dutch Emissions Authority (NEa). Customs checks this at the import declaration: without a valid authorisation, the goods are not released. And the application procedure can take up to 120 days — so waiting until the first shipment is under way is not an option.
Then there is the data side: the annual CBAM declaration requires emissions data from the producer, or otherwise the default values published by the European Commission. That calls for agreements with suppliers outside Europe — and for an import process in which the CBAM number is included in the customs declaration as standard.
What companies often get wrong about CBAM
The first misconception: "CBAM has been postponed." Not true — the definitive phase simply started on 1 January 2026. What has shifted is the payment moment: CBAM certificates are only sold and surrendered from 2027, covering the imports of 2026. Today's obligations — authorisation, registration, data structure — are already running, even though the bill follows later.
The second misconception: "CBAM applies to all imports." No: it concerns six groups of goods — iron and steel, cement, fertilisers, aluminium, electricity and hydrogen — plus the exemption up to 50 tonnes per calendar year. Do note two things: the threshold applies per importer across all CBAM goods combined, and the exemption does not apply to electricity and hydrogen.
The third misconception: "my forwarder handles that automatically." Responsibility lies with the importer. With direct representation — the usual arrangement — you remain the CBAM declarant yourself and file the annual declaration yourself. A forwarder like TOP does make sure the authorisation and CBAM number are correctly included in the customs declaration and helps set up the data process, but clear agreements in advance are essential.
Practical example
A Rotterdam trading company imports around 700 tonnes of steel profiles from Turkey each year — well above the threshold. The company applied for its authorisation as a CBAM declarant with the NEa in good time and requests emissions data per production batch from its supplier. TOP handles the import declarations and makes sure the CBAM account number is included in each one as standard, so Customs can release every shipment immediately. Before 30 September 2027, the company files its first CBAM declaration covering 2026 and surrenders the corresponding certificates. No surprises at the border, no standstill.
CBAM in two phases: what has changed?
CBAM was introduced step by step. The transitional phase was about learning to report; since 1 January 2026 binding obligations apply. Below, both phases are set out side by side.
CBAM in facts: sources and methodology
The facts below come from the Dutch Emissions Authority (NEa) and Dutch Customs, and were verified for this page in August 2026 — after the amending regulation of October 2025.
Threshold: 50 tonnes per year — Importers bringing in less than 50 tonnes of CBAM goods per year are exempt from the CBAM obligations; their share of total CBAM emissions is less than 1 percent. The exemption does not apply to hydrogen and electricity.
Source: NEa, CBAM legislation (in Dutch)
6 groups of goods — CBAM applies to iron and steel, cement, fertilisers, aluminium, electricity and hydrogen; the complete list of commodity codes is in Annex I of the regulation. Above the threshold, authorisation as a CBAM declarant is mandatory — without it, Customs does not accept the import declaration, and the application takes up to 120 days.
Source: Dutch Customs, CBAM (in Dutch)
Declaration by 30 September 2027 — Anyone importing more than 50 tonnes of CBAM goods in a year files a declaration in the CBAM registry by 30 September of the following year and surrenders sufficient certificates; the first declaration covers 2026. The price per tonne of CO₂ equals the price in the European emissions trading system.
Source: NEa, what is CBAM (in Dutch)
What TOP means for your CBAM compliance
TOP advises you on understanding and applying the CBAM rules in your import process. It starts with the basic questions: do your goods fall under Annex I, do you exceed the 50-tonne threshold, and is the authorisation as a CBAM declarant arranged in time? TOP then helps set up the data process: which emissions data do you request from suppliers, and when do you fall back on the European Commission's default values?
In execution, TOP makes sure CBAM runs seamlessly within the customs handling: the CBAM account number is correctly included in every import declaration, so Customs can release shipments immediately. If you want TOP to clear goods on behalf of your company, you can arrange the authorisation via apply for direct representation — in which case you remain the CBAM declarant as importer — with real-time insight via the TOP platform with API integrations.
Want to know what CBAM means for your goods flows? Request a customs quote, prepare your shipment via book a shipment, or schedule an introduction with TOP.
Which companies is TOP suitable for?
TOP is suitable for companies importing CBAM goods or considering doing so. These can be SMEs hovering around the 50-tonne threshold who want to know where they stand, but also multinationals with large steel or aluminium flows that need to secure the complete data and certificate process.
Boards mainly want no shipments stranded at the border and no unexpected CO₂ costs. Logistics managers want the authorisation and declaration process simply taken care of. Procurement and compliance look at supplier emissions data and cost-price effects per product. TOP understands that these interests come together in one well-prepared import process.
That is why TOP works in an advisory and practical way. No unnecessary jargon, but clear explanations of obligations, documents and next steps. For general developments in the transport sector, TOP also refers where relevant to industry information from Transport en Logistiek Nederland.
TOP is not a standard freight forwarder
TOP helps companies with a practical combination of customs matters, sea freight, air freight, intermodal transport, warehousing, rail and barge. This makes TOP particularly suitable for entrepreneurs and logistics teams who want understandable advice on importing, exporting and new obligations such as CBAM, without complicated jargon. Its strength lies in organising, explaining and following up on the entire logistics chain.
Frequently asked questions about CBAM
What is CBAM?
CBAM (Carbon Border Adjustment Mechanism) is the EU's carbon border correction mechanism. Importers pay a CO₂ price on the emissions released during the production of certain goods outside the EU, comparable to what EU producers pay under the emissions trading system.
Which goods does CBAM apply to?
Six groups of goods: iron and steel, cement, fertilisers, aluminium, electricity and hydrogen. The complete list of commodity codes is in Annex I of the European regulation.
Does CBAM also apply to small importers?
Usually not any more: since 1 January 2026, importers bringing in less than 50 tonnes of CBAM goods per calendar year are exempt. The exemption does not apply to electricity and hydrogen, and you are responsible for monitoring the threshold yourself.
What is an authorised CBAM declarant?
An importer (or indirect customs representative) authorised by the NEa to import CBAM goods above the threshold. Customs checks this at the import declaration; without authorisation the goods are not released. The application takes up to 120 days.
When do I have to buy CBAM certificates?
From 2027, covering the imports of 2026. The first annual CBAM declaration must be filed by 30 September 2027, with sufficient certificates surrendered. The price per tonne of CO₂ follows the price in the European emissions trading system.
Who enforces CBAM in the Netherlands?
The Dutch Emissions Authority (NEa) and Customs together, with the European Commission in the background. Customs checks the authorisation at the border; the NEa supervises compliance and can impose fines.
Conclusion: CBAM is already running — make sure your process is ready
CBAM has not been postponed and is not optional: the definitive phase has been running since 1 January 2026, Customs checks at the border and the first declaration with certificates follows in 2027. Anyone exceeding 50 tonnes must have the authorisation, the supplier data and the declaration process in order now.
TOP helps companies build CBAM into their existing import process: clear steps, a customs declaration in which the CBAM number is included as standard, and clear agreements on who does what. That way, your imports keep moving — under the new rules too.
Make your imports CBAM-proof with TOP
Want to know whether your goods fall under CBAM and what needs to be arranged before your next shipment? TOP is happy to take a look with you.
Request a customs quoteWant to know more about Trans Ocean Pacific forwarding? Visit the TOP homepage.
Last updated: August 2026. Sources: Dutch Emissions Authority (NEa) and Dutch Customs. Online findability and AI readiness of this page in collaboration with HEF Digital.