CBAM timeline: from transitional reporting to full phase-in
CBAM started as a reporting-only obligation in October 2023, became a financial obligation on 1 January 2026, and applies in full by 2034. Certificate sales open on 1 February 2027, and the first annual CBAM declaration — covering 2026 imports — is due by 30 September 2027 (Regulation (EU) 2023/956; Regulation (EU) 2025/2083).
Last updated: 2 July 2026Sources: Regulation (EU) 2023/956Regulation (EU) 2025/2083COM(2025)989 (European Commission proposal)European Commission — CBAM
What happened in the transitional period (2023–2025)?
From October 2023 to the end of 2025, importers of CBAM goods reported the embedded emissions of their imports quarterly, without buying certificates or making payments (Regulation (EU) 2023/956).
The transitional period existed to build the data and habits the financial phase relies on: identifying covered goods, collecting emissions data from suppliers, and practising the reporting workflow.
What changed on 1 January 2026?
The definitive period began: importing CBAM goods now requires authorised CBAM declarant status, and the emissions embedded in covered imports carry a real cost (Regulation (EU) 2023/956, as amended).
Regulation (EU) 2025/2083 also introduced the 50-tonne de-minimis threshold — importers below 50 tonnes of cumulative net mass of CBAM goods per legal entity per calendar year stay outside the main obligations, with electricity and hydrogen excluded from the exemption.
During 2026, obligations accrue but certificates are not yet on sale; purchases and surrender follow in 2027.
What happens in 2027?
2027 is the year CBAM's financial mechanics start moving:
- 1 February 2027 — CBAM certificate sales open (Regulation (EU) 2025/2083).
- 30 September 2027 — the first annual CBAM declaration is due, covering 2026 imports, together with the surrender of certificates (Regulation (EU) 2025/2083).
- From 2027, certificate prices move from quarterly publication to weekly publication (Regulation (EU) 2025/2083).
What is proposed for 2028?Proposal — not law
COM(2025)989 proposes extending CBAM to around 180 further downstream product categories from 1 January 2028.
This reflects a legislative proposal (e.g. COM(2025)989) that has not been adopted. Scope, product lists, and dates may change or may not enter into force.
How does CBAM ramp up to 2034?
CBAM phases in as free allocation under the EU ETS phases out. The CBAM factor scales the obligations: it starts low in 2026 and rises until CBAM applies in full by 2034 (Regulation (EU) 2023/956).
In practice this means the certificate cost attached to a tonne of imported goods grows year by year, even if the certificate price itself stayed flat.
How can importers keep track?
Most CBAM dates attach to the calendar year of import, so which deadlines matter for a given company depends on when its goods cleared customs. CBAM Pulse is building a deadline planner that lays this out per import year — it is not live yet, and the planned tools page shows its status.