CBAM importer checklist for 2026: a practical preparation sequence
This is a practical preparation sequence for importers in 2026, not a legal checklist or a statement that any step makes a business ready. A workable order: identify which goods are CBAM goods by CN code, check whether the 50-tonne threshold could be relevant, consider the authorised CBAM declarant question, start collecting supplier emissions data, track the certificate-price and deadline timeline, and assign an internal owner plus adviser review (Regulation (EU) 2023/956; Regulation (EU) 2025/2083).
Last updated: 4 July 2026Sources: Regulation (EU) 2023/956Regulation (EU) 2025/2083EC DG TAXUD — Price of CBAM certificatesEuropean Commission — CBAM
How to use this sequence
The steps below are an order of work, not a compliance form. Working through them helps you understand where CBAM touches your imports; it does not by itself make a business ready, and none of it replaces advice specific to your situation.
1. Identify CBAM goods by CN code
Start from what you import. Check which of your goods are CBAM goods by their 8-digit CN code against Annex I of Regulation (EU) 2023/956 — the goods checker is a quick way to test individual codes.
2. Check whether the 50-tonne threshold is relevant
Regulation (EU) 2025/2083 introduced a 50-tonne de-minimis threshold based on cumulative net mass per legal entity per calendar year, with electricity and hydrogen excluded from the exemption. The threshold checker shows how that cumulative test could apply to your volume.
3. Consider the authorised declarant question
Importing CBAM goods in the definitive period is tied to authorised CBAM declarant status, applied for through the national competent authority (Regulation (EU) 2023/956). Work out early who in your import chain would hold that role — the importer of record, or an indirect customs representative.
4. Start supplier emissions data collection
Embedded-emissions data mostly comes from suppliers and tends to arrive slowly. Identify the relevant suppliers, map goods to CN codes, request emissions data with supporting documents, and version what you receive.
5. Track the price and deadline timeline
Keep the 2026–2027 dates in view: quarterly certificate-price publication during 2026 moving to weekly from 2027, certificate sales opening in 2027, and the first annual declaration for 2026 imports. The deadline planner lists the dates with sources, and the certificate price tracker carries the current published figure.
6. Assign an internal owner and adviser review
CBAM preparation spans customs, procurement, and finance, so it helps to name someone who owns it internally and to line up review with a qualified adviser or your national competent authority for anything specific to your business.