Since 1 January 2026, the EU's carbon border adjustment mechanism CBAM has been in its definitive phase. Importers bringing more than 50 tonnes of iron and steel, aluminium, cement or fertilisers into the EU per year need authorised CBAM declarant status and will surrender certificates for embedded emissions from 2027, first due by 30 September 2027. FR8 Logistik GmbH in Hamburg provides the customs foundation through import clearance and plans shipments with CBAM in mind.

For three years, CBAM was a reporting duty without an invoice. That is over: with the turn of the year, the transitional phase ended, and the border adjustment became a cost factor with declarant status, registry account and certificates. At the same time, the EU simplified the system considerably with the omnibus regulation (EU) 2025/2083: the old 150 euro per-shipment trigger gave way to a threshold of 50 tonnes per importer and year, which exempts most small importers while still keeping around 99 percent of covered emissions in the system.

For shippers, CBAM is the counterpart to the transport side: while the EU ETS prices the emissions of the sea transport, CBAM prices the emissions embedded in the product itself. This guide explains who is affected, which deadlines and documents apply, and how to plan shipments with CBAM in mind.

50 tonnes

Threshold per importer and year for steel, aluminium, cement and fertilisers

around 99%

of covered emissions remain in the CBAM system despite the threshold

3,879

Projects completed by FR8 Logistik GmbH in 2025

16,388 TEU

Containers loaded by FR8 Logistik GmbH in 2025

Who CBAM affects and when the obligation arises

CBAM covers imports of iron and steel, aluminium, cement and fertilisers, plus electricity and hydrogen. The customs moment is decisive: the obligation arises with the release into free circulation, not with the order, the shipment or the arrival. And it falls on the importer, the company having the goods released into free circulation, not on the manufacturer and not on the freight forwarder.

The 50-tonne threshold applies to the four goods groups combined and per calendar year. Two details are often overlooked: the threshold does not apply to electricity and hydrogen. And anyone exceeding it during the year pulls all of that year's imports into CBAM, not just the volume above 50 tonnes. Volume monitoring across the year is therefore mandatory homework for anyone operating near the threshold.

Deadlines and obligations at a glance

Date

What applies

1 January 2026

Start of the definitive regime: imports above the threshold require authorised CBAM declarant status

31 March 2026

Transitional rule: anyone who filed the declarant application by this date may continue importing while it is processed

February 2027

Start of certificate sales via the central EU platform, retroactively covering the emissions of 2026 imports

30 September 2027

First annual CBAM declaration including certificate surrender for the 2026 import year; the 30 September deadline then applies every year

The cost mechanics are linked to emissions trading: the price of CBAM certificates for 2026 imports follows the average value of EU ETS allowances in 2026. Carbon prices already paid in third countries are credited. The burden per shipment therefore depends on three factors: the volume of goods, the manufacturer's emission intensity, and the ETS market price. There is no flat rate per tonne, and that is precisely where the lever sits: a lower-emission supplier reduces CBAM costs directly.

Documents and data: what importers must collect now

• Declarant status and registry account: the application for authorisation as a CBAM declarant runs through the national portal; without the status, no imports above the threshold.
• Manufacturers' emission data: the embedded emissions per commodity code come from the supplier in the third country. Where no reliable manufacturer data exists, default values apply, and they are usually less favorable. The supplier query therefore belongs in the procurement process, not in September 2027.
• Customs data per import: commodity code, origin, mass and customs value from the import declaration form the skeleton of every CBAM declaration. Clean clearance data is half the declaration.
• Evidence of carbon prices paid: anyone already paying CO2 levies in the country of origin needs the documentation for crediting.

Cargo planning: three CBAM-aware levers

First, volume timing: anyone close to the 50-tonne threshold plans annual volumes deliberately instead of breaching them by accident in December. Second, supplier choice on the affected lanes: especially in the growing container imports from India, CBAM will play the third cost role for steel and aluminium goods alongside duty rate and freight rate, while the EU-India trade agreement relieves the duty side. Both effects belong in the same calculation.

Third, the timing of release: because CBAM is triggered by release into free circulation, the bonded warehouse acts as a pacing tool. Goods sitting in a bonded warehouse have not yet triggered CBAM; the effect arises only upon withdrawal. Importers can pace incoming goods and place the withdrawal in the year that fits their calculation. How interim storage in a bonded warehouse works in practice is covered in our guide to warehousing in Hamburg. The warehouse cannot replace CBAM obligations, but it shifts the timing and creates predictability.

What FR8 Logistik GmbH delivers for CBAM-liable imports

FR8 Logistik GmbH is an internationally active sea freight forwarder based in Hamburg, a member of the DSLV (German Association of Freight Forwarding and Logistics) and the Association of Hamburg Freight Forwarders (VHSp). In 2025 we completed 3,879 projects and loaded 16,388 TEU. The CBAM declaration itself sits with the importer, but its foundation is built with us: with customs clearance and warehousing from a single source, we deliver clean import data per shipment, interim storage in a bonded warehouse for volume timing, and one fixed contact person who thinks clearance, warehousing and transport together.

If you import steel, aluminium or other CBAM goods and want to align your chain for 2026, send us the route, the goods and the annual volume. You can request a quote and receive a concrete response within 24 hours.

Frequently asked questions about CBAM in 2026

Who is affected by CBAM from 2026?
CBAM affects companies importing iron and steel, aluminium, cement, fertilisers, electricity or hydrogen into the EU. Since 1 January 2026 the definitive regime has been live: anyone exceeding the volume threshold needs authorised CBAM declarant status and will have to surrender certificates for the emissions embedded in the product. The obligation arises with the release into free circulation, not with the order or the shipment.

Does CBAM also apply to small import volumes?
Since the omnibus simplification (Regulation (EU) 2025/2083), a threshold of 50 tonnes per importer and year applies to iron and steel, aluminium, cement and fertilisers combined. Importers staying below it are exempt from declarant status, declaration and certificates. The threshold does not apply to electricity and hydrogen. Important: exceeding the threshold during the year brings all of that year's imports into CBAM, not just the volume above 50 tonnes.

Which deadlines apply for CBAM in 2026 and 2027?
The definitive regime has applied since 1 January 2026. Anyone who applied for declarant status by 31 March 2026 may continue importing while the application is processed. The sale of CBAM certificates begins in February 2027 and covers the emissions of 2026 imports. The annual CBAM declaration including certificate surrender is due by 30 September of the following year, so for the 2026 import year by 30 September 2027.

How are CBAM costs calculated?
CBAM prices the emissions embedded in the product, meaning the CO2 from production per tonne of goods. The certificate price is linked to the EU emissions trading system: for 2026 imports, the average value of EU ETS allowances in 2026 applies. Carbon prices already paid in third countries are credited. The burden per shipment therefore depends on volume, the manufacturer's emission intensity and the ETS market price; there is no flat rate per tonne.

Does a bonded warehouse help with CBAM planning?
Yes, as a timing tool. CBAM is triggered by the release into free circulation. Goods in a bonded warehouse have not yet been released, so the CBAM effect only arises upon withdrawal. Importers can pace incoming goods across the year, keep an eye on the threshold and place the withdrawal in the year that fits their calculation. The bonded warehouse cannot replace CBAM obligations, but it shifts the timing.

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