CBAM, answered briefly and honestly
The questions importers ask us most often. As of June 2026 and without warranty.
The transitional phase with reporting obligations only ran from October 2023 to the end of 2025. Since 1 January 2026 the definitive regime applies. Imports of CBAM goods from 2026 trigger financial obligations, even though the certificates are only bought and surrendered later.
Since October 2025 a de minimis threshold of 50 tonnes of cumulative net mass per year and importer applies. Anyone below it is exempt from reporting, declarant status and certificates. That relieves a large share of smaller importers. Important: this exemption does not apply to hydrogen and electricity.
The sale of CBAM certificates begins, as things stand, on 1 February 2027. The first annual CBAM declaration together with the surrender of certificates is scheduled for 30 September 2027 and covers imports in 2026. The financial effect therefore applies retroactively to 2026.
The price tracks the EU Emissions Trading System. For 2026 it is formed as a quarterly average of ETS auction prices, from 2027 as a weekly average. At the start of 2026 the reference value was in the order of around 75 euros per tonne of CO₂ equivalent. This value fluctuates considerably and is not a guarantee.
Above the de minimis threshold, only those who hold the status of authorised CBAM declarant may import CBAM goods. The competent national authority in your member state is responsible for this. The status is applied for and has a processing time. Anyone who applies in good time can, under conditions, continue importing while the application is pending.
Where no actual, verifiable emission values from the manufacturer are available, default values apply. These are deliberately conservative and continue to rise over the years. In many cases real supplier data leads to a lower emissions basis and therefore to lower certificate costs. Data collection is therefore rarely bureaucracy for its own sake, but often the biggest cost lever.
No. We provide operational preparation, data and organisational services. We provide no legal, tax or customs advice, file no declarations on your behalf and do not represent you before the authorities. Where such services are needed, we work with your advisers or arrange the contact.
The self-test gives a first orientation immediately. The Rapid Screening takes two to three working days. We deliver the full CBAM decision file in seven working days from receipt of your import data, at a fixed price.
No. All information on CBAM is provided to the best of our knowledge as of June 2026 and without warranty. Dynamic values such as ETS prices, default values and deadlines can change. The applicable legal acts and the competent authorities are always decisive. Our service does not replace a legal, tax or customs assessment.
We process your import data exclusively to provide the agreed service, confidentially and in line with the GDPR. Details are in our privacy policy.
EnergyFlow Regulatory Desk is a service of EnergyFlow GmbH. We provide operational preparation, data and organisational services around CBAM. We provide no legal, tax, customs or certification advice.
Question not covered?
Ask us directly. In an initial call or by message, both without obligation.