CBAM readiness checklist

A practical checklist of the areas EU importers and their advisers typically work through when preparing for CBAM — covered goods and CN scope, the 50-tonne threshold, authorised-declarant setup, supplier emissions data, certificate-price cost planning, and the key 2026–2027 dates. Each item links to an official source or to a CBAM Pulse tool that shows the source and effective date. It is a preparation aid, not a determination: working through it does not mean you are compliant or ready, and nothing here is legal, tax, or customs advice. Nothing is stored, and no account is required.

Last updated: 2026-07-03Sources: Regulation (EU) 2023/956 (consolidated text)Regulation (EU) 2025/2083EC DG TAXUD — Carbon Border Adjustment MechanismEC DG TAXUD — Price of CBAM certificates

0 of 22 preparation areas reviewed. Ticks are a working aid only — they are not saved and do not indicate compliance or readiness.

1. Goods and CN scope

Work out which of the goods you import fall within CBAM's covered sectors, before anything else.

Identify the CN codes of the goods you import and note which fall within CBAM's covered sectors (iron and steel, aluminium, cement, fertilisers, hydrogen, and electricity).
See: CN goods checker (shows the source and effective date)
Keep a note of any proposed scope changes that could add or remove product groups, so a later change does not catch you unprepared.
See: CBAM updates feed (shows the source and effective date)
Consider how goods entering under special customs procedures (for example inward processing) are treated, and confirm the detail with your customs broker.
Source: Regulation (EU) 2023/956 (consolidated text)

2. Import volume and the 50-tonne threshold

Estimate your import volumes to see whether the de-minimis exemption could be relevant to your situation.

Estimate your cumulative net mass of CBAM goods per legal entity per calendar year, to see whether the 50-tonne de-minimis exemption could apply.
See: 50-tonne threshold checker (shows the source and effective date)
Check the threshold against the importing legal entity / EORI for the calendar year, not per shipment or per supplier.
See: 50-tonne threshold checker (shows the source and effective date)
Note that electricity and hydrogen are excluded from the 50-tonne exemption.
Source: Regulation (EU) 2025/2083

3. Authorised declarant preparation

Understand the authorised CBAM declarant role and who would hold it for your imports.

Understand the authorised CBAM declarant role and identify who in your supply chain would hold it for your imports.
Source: Regulation (EU) 2023/956 (consolidated text)
Identify your National Competent Authority and note their published guidance and contact points.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Plan who on your side would need access to the relevant CBAM systems and accounts, and how that access would be requested.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism

4. Supplier emissions data

Map the embedded-emissions data you would need from suppliers, and start the conversation early.

Map which suppliers you would need embedded-emissions data from, and begin those conversations early.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Understand when default values may be used and when actual, verified emissions data is expected instead.
Source: Regulation (EU) 2023/956 (consolidated text)
Set up a way to collect, store, and version supplier emissions data and the supporting documentation behind it.
Source: Regulation (EU) 2023/956 (consolidated text)

5. Certificate price and cost planning

Use officially published prices for any cost planning — only Commission figures are authoritative.

Follow officially published CBAM certificate prices when planning cost exposure — only figures published by the European Commission are authoritative.
See: Certificate price tracker (shows the source and effective date)
Note that for 2026 the certificate price is published quarterly, with weekly publication from 2027.
Source: EC DG TAXUD — Price of CBAM certificates
Treat any cost planning figure as indicative only — actual costs depend on verified emissions data and your specific circumstances.
See: Certificate price tracker (shows the source and effective date)

6. 2026–2027 deadlines

Put the key dates for the 2026 import cycle on your internal calendar.

Note that the CBAM definitive (paying) period applies from 1 January 2026.
See: Deadline planner (shows the source and effective date)
Note that the sale of CBAM certificates begins on 1 February 2027.
See: Deadline planner (shows the source and effective date)
Note that the first annual CBAM declaration, covering 2026 imports, falls due on 30 September 2027 together with certificate surrender.
See: Deadline planner (shows the source and effective date)

7. Internal owner and advisor review

Decide who owns CBAM preparation internally and when to bring in a qualified adviser.

Assign an internal owner for CBAM preparation and agree when to involve a qualified adviser.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Verify every date and figure against the official source before relying on it in a decision.
Source: Regulation (EU) 2023/956 (consolidated text)
Consult a qualified adviser and your National Competent Authority for your specific situation.
Source: EC DG TAXUD — Carbon Border Adjustment Mechanism
Keep watch on new CBAM regulatory updates as the rules and guidance continue to evolve.
See: CBAM updates feed (shows the source and effective date)

This result is generated from published official data (sources and effective dates shown above) and depends on the accuracy of your inputs. It is informational only and is not a determination of your legal obligations. Verify the final CN classification and your obligations with your customs broker or National Competent Authority.

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CN goods checker
50-tonne threshold checker
Certificate price tracker
Deadline planner
CBAM updates feed
Methodology: how our data is sourced and versioned