CBAM (“Carbon Border Adjustment Mechanism”) is the EU’s new system for recording the CO₂ emissions embedded in certain imported goods.
Companies importing such goods into the EU must declare the related emissions and, in the future, purchase so-called CBAM certificates.
The aim is to create a level playing field and prevent “carbon leakage” – the relocation of emissions to countries with lower environmental standards.
CBAM applies to all companies importing goods from certain carbon-intensive sectors into the EU or responsible for such imports.
The product groups currently covered are iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.
Many companies use digital CBAM solutions or software to automatically collect, verify and report emission data.
A tool that provides comprehensive compliance coverage is the MAYGREEN CBAM Facilitator.
CBAM currently applies to the product groups cement, iron & steel, aluminium, fertilisers, electricity and hydrogen.
The European Commission will review in early 2026 whether the scope of CBAM should be extended to additional carbon-intensive products.
Such an extension is being prepared but has not yet been adopted.
During the reporting phase, starting from Q3 2024, the use of actual data was mandatory.
Companies had to make all reasonable efforts to obtain this data from their suppliers in third countries.
From 2026 onwards, the European Commission will provide default values for certain products, sectors and countries.
Nevertheless, data collection from suppliers will still be required in many cases.
Digital tools such as the MAYGREEN CBAM Facilitator support companies in requesting, recording and structuring supplier data and in preparing, generating and submitting the CBAM report automatically.
CBAM certificates are digital units with which companies account for the CO₂ emissions embedded in imported goods.
They function similarly to the EU Emissions Trading System (EU ETS): for each tonne of imported CO₂, the corresponding certificates must be purchased and surrendered via the CBAM Registry of the European Commission.
The price of the certificates is based on the current EU ETS carbon price and is adjusted regularly.
This ensures that imported goods are subject to the same carbon costs as products manufactured within the EU.
From 1 January 2026, only authorised CBAM declarants may import goods from CBAM-covered sectors into the EU.
An exception applies to non-authorised companies only if they have submitted an application for authorisation by 31 March 2026.
Companies importing CBAM goods must purchase CBAM certificates and surrender them via the CBAM Registry of the European Commission.
Under the CBAM Omnibus I reform (COM (2025) 87), a new mass-based de-minimis threshold of 50 tonnes per year applies:
- Companies importing more than 50 tonnes of CBAM goods per year must hold authorisation or submit an application by 31 March 2026.
- Companies importing less than 50 tonnes (excluding hydrogen and electricity) may import without authorisation but must indicate the exemption in their customs declaration.
- For hydrogen and electricity, the authorisation requirement always applies, regardless of the quantity.
CBAM is supervised by the European Commission and the national CBAM authorities.
In Germany, the responsible body is the German Emissions Trading Authority (DEHSt) at the Federal Environment Agency (UBA).
It verifies whether reports are submitted correctly and certificates surrendered according to the reported emissions.
Imports from countries participating in the EU ETS or operating an equivalent carbon-pricing system – such as Norway, Iceland, Liechtenstein and Switzerland – are exempt.
In addition, a threshold of 50 tonnes per year applies: Companies below this threshold do not have to surrender certificates but remain subject to reporting obligations.
The planned CBAM Omnibus I reform (COM (2025) 87) introduces a free-allowance threshold of 50 tonnes of CBAM goods per year.
Companies below this limit are not required to purchase certificates but must continue reporting.
For hydrogen and electricity, the authorisation requirement applies regardless of the quantity.
A complete CBAM report requires the following information and access rights:
- Customs tariff numbers (CN codes) of the imported goods
- Quantities of imported products
- Emission data of the producers (direct and, where applicable, indirect emissions)
- Evidence of any carbon price paid in the country of origin
- Access to the EU CBAM Registry
Many companies digitalise this process using CBAM software such as the MAYGREEN CBAM Facilitator to efficiently collect data, automate calculations and ensure timely submission of reports.
Whether your company falls under the CBAM Regulation depends on whether you import goods from third countries into the EU and which products are covered.
Currently, CBAM applies to iron, steel, aluminium, cement, fertilisers, hydrogen and electricity.
We would be happy to support you in a non-binding initial consultation to assess whether – and to what extent – your company is affected.