If you export steel, aluminium, cement, fertiliser, hydrogen or electricity to the EU, the rules you’ve been operating under since October 2023 just changed. Here’s what’s actually different, in order of what hits you first.

The transitional phase is over

From 1 October 2023 to 31 December 2025, EU importers of your goods only had to report embedded emissions. No certificates, no verification requirement, no authorisation to hold. That phase ended. The definitive phase started 1 January 2026, and it is not a future date — it is the phase you are in right now.

Three things are now binding

Authorisation. EU importers of covered goods must hold authorised CBAM declarant status before they can bring your product in. If your buyer hasn’t sorted this, that’s now a problem for both of you.

Verified reporting. From 2026, an importer may only declare actual (supplier-specific) embedded emissions — as opposed to the EU’s default values — if the figure has been signed off by an independent verifier accredited by an EU national accreditation body. Verifiers are required to visit the installation. The first CBAM verifiers are expected to receive accreditation around September 2026.

Certificates — on a schedule, not all at once. Certificate sales begin 1 February 2027. The first declaration and surrender deadline is 30 September 2027, covering emissions embedded in goods imported during 2026. Importantly, the number of certificates actually owed is reduced by the free allocation still granted to EU producers of the same goods — and that free allocation is being phased out gradually, starting at a 2.5% reduction in 2026 and rising to a full 100% (no offset left) by 2034. This year’s bill is a fraction of what it becomes.

What this means in practice

You don’t need to panic about a certificate invoice landing next week. You do need your authorisation, reporting and verification chain sorted now, because the accreditation and verification process takes months, and the definitive phase doesn’t wait for you to be ready.

See the full CBAM page for what a filing actually requires, or run the exposure calculator against your own export tonnage.