kopik
Create
EnvironmentVerified by Kopik: Official sources reviewed and answers tested by Kopik

CBAM — EU Carbon Border Adjustment Mechanism: definitive period obligations

Covers Regulation (EU) 2023/956 establishing the CBAM (consolidated after the October 2025 Omnibus simplification), the definitive-period implementing and delegated acts on declarant authorisation, the registry, embedded-emissions methodology, verification, certificate pricing and free-allocation adjustment, the 2023-2025 transitional reporting regime, and the Commission's 2026 guidance for importers, operators and verifiers. Built for importers of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, their customs representatives, and non-EU producers, to answer precise questions on scope, the 50-tonne de minimis threshold, declaration deadlines, certificate purchase/surrender and emissions calculation. Numeric default-value tables and the not-yet-adopted carbon-price-paid deduction act are out of scope. Curated by Kopik from public sources: EUR-Lex / Publications Office of the European Union and European Commission (reuse authorised, Decision 2011/833/EU).

Ask your question

Free account required

Each question stands alone · 1 free a month, then with a subscription.

Answers are written by a language model solely from this base's documents, with numbered sources. They can be wrong and aren't legal, medical or financial advice: check the sources before any important decision.

This assistant answers questions on the EU Carbon Border Adjustment Mechanism (CBAM) in its definitive period: which imports are covered, who must declare, how embedded emissions are calculated and verified, and how CBAM certificates work. It is built for EU importers, customs representatives and non-EU producers of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Answers draw on Regulation (EU) 2023/956 as amended by the 2025 Omnibus simplification, its implementing and delegated acts published on EUR-Lex, and the European Commission's guidance documents.

Which goods and countries does CBAM cover?

CBAM applies to goods from the cement, iron and steel, aluminium, fertiliser and hydrogen sectors, and to electricity, as listed in Annex I of the Regulation. To know whether a product is covered, compare its CN code with that list. Where Annex I gives fewer than 8 digits, every CN code starting with those digits is covered.

Some origins are outside the scope. Annex III lists Iceland, Liechtenstein, Norway and Switzerland, as well as certain territories such as Büsingen, whose goods are not subject to CBAM.

Non-EU producers are also concerned when their products reach the EU indirectly: sold through traders, or used as precursors by another manufacturer whose CBAM goods are then exported to the EU.

The annual CBAM declaration

From the definitive period, each authorised CBAM declarant submits one CBAM declaration per year through the CBAM registry, by 30 September, covering the preceding calendar year. The first declaration is due in 2027 for the year 2026.

The declaration states the total quantity of each type of goods imported (in megawatt-hours for electricity, in tonnes for other goods), the total embedded emissions, the number of CBAM certificates to surrender, and, where applicable, copies of verification reports issued by accredited verifiers.

The declarant may delegate the submission of declarations to a person acting on its behalf and in its name, but remains responsible for compliance.

How embedded emissions are determined

Embedded emissions cover the direct emissions of the production process, the embedded emissions of precursors and, for goods listed in Annex I but not in Annex II, indirect emissions. In CBAM, "indirect emissions" refers only to the electricity consumed, not to heat.

Emissions can be based on actual data from the producing installation or on default values. Default values are set at the average emission intensity of each exporting country, increased by a mark-up. For imported electricity, default values apply unless the declarant shows that the criteria for actual emissions in Annex IV are met.

There is no threshold for leaving out small amounts of precursors. A precursor originating in the Union or in an exempted country counts as zero embedded emissions, but its identity and quantity must still be monitored and reported.

Verification of actual emissions

When a declaration relies on actual emissions, the total must be verified by a verifier accredited under the CBAM rules, following the principles of Annex VI. A declarant can use verified data that a registered non-EU installation has shared through the CBAM registry.

In the first year subject to verification, a physical site visit of the installation is required in all cases. In a second consecutive year, the verifier may replace it with a virtual visit or waive it if specific criteria are met, and only if a physical visit took place the previous year. Physical visits must happen at least every two years.

Frequently asked questions

Does CBAM apply to steel imported from Norway or Switzerland?

No. Annex III of the CBAM Regulation lists Iceland, Liechtenstein, Norway and Switzerland as countries whose originating goods are outside the scope of the Regulation. The rule is based on the origin of the goods, not on where they were shipped from.

What happens if a CBAM declaration is not filed?

The Commission assesses the declarant's obligations on the information it holds and establishes a preliminary calculation of the certificates that should have been surrendered, at the latest by 31 December of the year following the missed deadline. The competent authority of the Member State where the declarant is established then sets the definitive number of certificates owed. The same procedure applies when a declaration is found to be incorrect, in which case the Commission has until 31 December of the fourth year after its submission.

Who counts as the declarant for imported electricity?

Where transmission capacity for electricity imports is allocated through explicit capacity allocation, the person who was allocated the capacity and nominates it for import is regarded as the authorised CBAM declarant in the Member State where the import was declared. Imports are measured per border for periods of no more than one hour, with no deduction of exports or transit in the same hour.

Can default values differ between regions of the same country?

Yes, where objectively justified. The Regulation allows default values to be adapted to particular areas, regions or countries to reflect objective factors that affect emissions, such as prevailing energy sources or industrial processes. When reliable data are lacking for an exporting country, default values are based on the average emission intensity of the 10 exporting countries with the highest intensities for that type of goods.

How should a non-EU producer share emissions data with EU importers?

The recommended route is to register the installation in the CBAM registry (the O3CI module), upload verified emissions data once and share it with every declarant importing the goods. Registration also limits what declarants see to a summary of the emissions report. Without registration, the operator must send data to each party separately using the same emissions report template.

What was required before the definitive period started?

During the transitional period, from 1 October 2023 to 31 December 2025, importers only had reporting obligations. They submitted a quarterly CBAM report on the goods imported, no later than one month after the end of each quarter. No certificates had to be bought or surrendered.

For developers and agents

Embed / API / MCP

Connect this base to Claude, Cursor, ChatGPT or your own app. Each API or MCP request costs €0.10, charged to your Kopik credit (not charged if nothing is found). You need an API key: create one from your dashboard.

MCP for your agents

This base's MCP server URL (tools ask_base and search_base):

MCP URL
https://kopik.io/api/mcp?base=eu-cbam-carbon-border
Claude Code, Cursor and other clients
Claude Code
claude mcp add --transport http kopik-eu-cbam-carbon-border "https://kopik.io/api/mcp?base=eu-cbam-carbon-border" --header "Authorization: Bearer kpk_…"
JSON config (mcpServers)
{
  "mcpServers": {
    "kopik-eu-cbam-carbon-border": {
      "url": "https://kopik.io/api/mcp?base=eu-cbam-carbon-border",
      "headers": {
        "Authorization": "Bearer kpk_…"
      }
    }
  }
}

REST API for your apps

mode is "answer" (written answer + sources) or "passages" (raw passages only). Add an optional maxPriceCents to cap the price: if the base costs more, the call is refused and nothing is charged.

curl
curl -X POST https://kopik.io/api/v1/bases/eu-cbam-carbon-border/query \
  -H "Authorization: Bearer kpk_…" \
  -H "Content-Type: application/json" \
  -d '{"question": "Your question here", "mode": "answer"}'

Getting started

  1. Create a key in your dashboard and top up your credit.
  2. Replace kpk_… with your key.
  3. Full details (responses, errors, JS and Python examples): developer docs.