Four general guides plus six sector guides: practical guidance with examples
On August 14, 2026, the European Commission published a series of 10 guidance documents to support compliance during CBAM's definitive period. The package comprises four general guides (No. 1: introduction to CBAM concepts; No. 2: a quick guide for non-EU operators; No. 3: calculation of embedded emissions; No. 4: calculation of the EU ETS free-allocation adjustment) and six sector guides (No. 5a–5f: cement, hydrogen, fertilizers, iron and steel, aluminium, and electricity). Each sector guide covers production processes, value chains, and monitoring and reporting considerations, with worked calculation examples. Its main audiences are operators of covered installations outside the EU, authorised CBAM declarants, and verifiers.
The shape of the definitive regime: January 2026 start, 50-tonne threshold, ETS-linked pricing
CBAM's definitive regime took effect on January 1, 2026. EU importers or indirect customs representatives are required to obtain Authorised CBAM Declarant status.
The threshold is clear. Importers bringing more than 50 tonnes of CBAM goods into the EU per year are legally required to apply for Authorised CBAM Declarant status. It is a single mass-based threshold applied uniformly across sectors. Smaller imports at or below 50 tonnes fall outside the obligation.
Start date
January 1, 2026. EU importers or indirect customs representatives must obtain Authorised CBAM Declarant status.
Threshold
Above 50 tonnes per year (single mass-based threshold, uniform across sectors) triggers the legal obligation to apply. At or below 50 tonnes is out of scope.
Certificate price
Linked to EU ETS auction prices (€/tonne CO2). Quarterly averages during 2026, shifting to weekly averages from 2027.
Six sectors
Cement, iron and steel, aluminium, fertilizers, electricity, hydrogen — each with its own specific requirements.
Application route
The National Competent Authority (NCA) of the member state where the importer is established. The NCA list was published on June 26, 2026.
The pricing method changes over time. Quarterly average EU ETS auction prices apply during 2026, moving to weekly averages from 2027. That the basis for estimating price volatility shifts across the year boundary is worth building into procurement plans.
The core issue for non-EU exporters: deducting a carbon price already paid
For companies outside the EU, this deduction mechanism is what determines the real burden. It is designed to avoid double payment alongside carbon pricing policies outside the EU, which means whether your country has a functioning carbon price translates directly into a cost difference.
But the existence of a scheme is not enough. Claiming the deduction requires documentation proving the carbon price already paid, which in turn presupposes properly verified and reported emissions data. Guide No. 4's treatment of how certificate surrender is adjusted for EU ETS free allocation reflects the complexity of that calculation: where an EU ETS participant receives free allocation, the CBAM surrender obligation is reduced accordingly.
The definitive period imposes emissions data verification obligations on operators. The Commission states explicitly that operators need appropriate processes in place to report actual emissions in preparation for verification, and positions verifiers as participants in the compliance cycle.
Next up: extension to downstream products under examination
Current CBAM covers primary materials such as iron and steel and aluminium, but the European Parliament is examining a Commission proposal to extend the scope to downstream steel and aluminium products. A briefing published by the European Parliamentary Research Service (EPRS) on July 6, 2026 for the Committee on International Trade (EPRS_BRI(2026)789314) analyses its content.
The proposal has three components.
Extension to downstream products
Widening scope from primary materials to processed goods. Finished and semi-finished goods manufacturers, not just material producers, could enter scope.
Anti-circumvention measures
Introducing measures to prevent circumvention of CBAM application.
Revised electricity emissions calculation
Revising how emissions embedded in electricity are calculated — directly affecting product carbon footprint calculations.
Revising electricity emissions intensity calculation feeds directly into product-level footprint figures. Companies that have focused only on materials need to track both the possibility of their products being captured downstream and the change in how electricity-derived emissions are calculated.
The international context
Multilateral dialogue on carbon pricing policy is also advancing. On June 24, 2026, the OECD held its Inclusive Forum on Carbon Mitigation Approaches (IFCMA). OECD Secretary-General Mathias Cormann and Deputy Secretary-General Fabrizia Lapecorella chaired, with participation at ministerial and director level including Korea's Vice Minister of Climate, Energy and Environment, Mexico's Director General of Climate Action Policy, Türkiye's Head of Carbon Pricing at the Ministry of Environment, Urbanisation and Climate Change, and South Africa's Deputy Minister Narend Singh.
Major emerging economies attending at that level indicates these governments treat carbon policy as a national priority. As border measures like CBAM spread, how an exporting country structures the domestic scheme that underpins deduction is becoming a matter of trade policy itself.
From a procurement standpoint, the question becomes whether a supplier's country has a carbon pricing scheme that could qualify for deduction, and whether that scheme's verification framework can withstand EU requirements. Not just whether a scheme exists, but the granularity of its MRV and the framework for its verifiers.