CBAM for US Exporters: What EU Buyers Need From You in 2026

Since January 1, 2026, covered steel, aluminum, cement, fertilizer, electricity and hydrogen entering the European Union carries a carbon cost that the EU importer has to report and pay for, unless its imports stay within the 50-tonne annual exemption, which does not apply to electricity or hydrogen. The Carbon Border Adjustment Mechanism, known as CBAM, puts the legal obligation on the EU importer, not on the US mill or plant. In practice the cost and the data burden travel back up the supply chain. EU buyers now ask their US suppliers for installation-level emissions data, and a supplier that cannot provide it leaves the buyer to fall back on the Commission’s default values.

This guide is for US exporters of CBAM goods and the logistics and compliance teams that support them. It covers what the definitive period changed, which goods are in scope and who pays, the exact data EU importers will request, how verification works, and the CBAM dates that matter through 2027.

What the Definitive Period Changed on January 1, 2026

CBAM was introduced in two phases under Regulation (EU) 2023/956. The transitional period ran from October 1, 2023 to December 31, 2025 and was a reporting exercise: importers filed quarterly reports on embedded emissions but paid nothing, and verification was optional. The definitive regime has applied since January 1, 2026. EU importers above the threshold now need authorization as CBAM declarants. From February 2027 they buy CBAM certificates priced off the EU Emissions Trading System, and each year they surrender certificates against the emissions embedded in what they imported the year before.

Regulation (EU) 2025/2083, the simplification package adopted in 2025, amended the original text before the financial phase started. Its most visible change is a single mass-based threshold that takes small importers out of scope, discussed below. The annual declaration requirement in Article 6(1) now applies as amended by that regulation. The Commission publishes a consolidated version of Regulation (EU) 2023/956 as amended by 2025/2083, and that consolidated text is the one EU buyers’ compliance teams work from.

The policy logic explains the data demand. CBAM exists to put the carbon price of imports on par with EU production, which pays under the EU ETS. Free allocation of ETS allowances to EU producers in the same sectors is being phased out between 2026 and 2033 while CBAM is phased in, and from 2034 the embedded emissions of CBAM goods are fully covered by certificates. Every year of that phase-in raises the stakes of the emissions number attached to a US shipment.

Covered Goods, the 50-Tonne Threshold and Who Pays

CBAM covers imports from six sectors: iron and steel, aluminum, cement, fertilizers, electricity and hydrogen. The precise scope is the list of Combined Nomenclature codes in Annex I to the CBAM Regulation, which includes some precursors and some downstream products of those sectors. CN codes share their first six digits with the HS, so a US exporter can screen the first six digits of its Schedule B numbers against Annex I as a first pass. Where Annex I lists fewer than eight digits, every CN code beginning with those digits is covered.

The de minimis exemption is set at 50 tonnes of net mass. Per the Commission’s Guidance No. 1 of August 2026, the threshold applies to the aggregate net mass of all CBAM goods, across all CN codes, imported by the same importer in the same calendar year. It is not per shipment and not per product. If an importer crosses 50 tonnes during the year, it becomes subject to all CBAM obligations for that year, including for goods imported before the threshold was crossed. The exemption does not apply to electricity or hydrogen.

The party that pays is the authorised CBAM declarant, which the Commission describes as the person lodging the customs declaration, usually the importer and in some cases the indirect customs representative. Each tonne of imported goods is the responsibility of exactly one declarant. For a US exporter selling on terms where the EU buyer clears customs, the buyer is the declarant. If the US seller takes on EU clearance, the question of who acts as declarant has to be settled before the first shipment, and it belongs in the same conversation as who pays EU import duties and taxes under the chosen Incoterm.

How the CBAM Obligation Is Calculated

The number of certificates an EU declarant must surrender starts with the embedded emissions of the imported goods, in tonnes of CO2 equivalent per tonne of product. Two reductions follow. The first is a free allocation adjustment that reflects the free ETS allowances an EU producer of the same good would still receive, based on a CBAM benchmark and a time-dependent factor that shrinks each year. The second is a deduction for any carbon price effectively paid in the country of production, net of rebates or compensation. If the result is negative, the obligation is zero.

In 2026 the certificate price is the quarterly average of EU ETS auction clearing prices, calculated under Implementing Regulation (EU) 2025/2548. The Commission published the first two quarterly prices at 75.36 euros per certificate for Q1 2026 and 75.28 euros for Q2 2026, each certificate corresponding to one tonne of CO2 emitted. From 2027 onward prices are published weekly. These figures are the reference EU buyers use when they price the CBAM cost into a purchase from a US supplier.

The embedded emissions figure is the main input a US exporter controls. The benchmark, the phase-in factor and the certificate price are set in Brussels. A buyer comparing two suppliers of the same hot-rolled coil or the same urea will see the difference almost entirely in the emissions data each one provides.

Data US Exporters Must Supply to EU Buyers

The Commission’s Guidance No. 2, a quick guide for non-EU operators, is direct about the flow: wherever CBAM goods end up imported into the EU, the importer will at some point contact the producer to gather embedded emissions data, and the producer must be prepared to provide it. That applies when a US plant sells to a trader who resells into the EU, and when the US product is a precursor that another producer turns into a CBAM good bound for the EU.

The operator's emissions report

Where embedded emissions are calculated from actual data, the producer prepares an annual operator’s emissions report and a summary of it, which under Article 10 of Implementing Regulation (EU) 2025/2547 must contain at least the information listed in the templates in Annex IV to that regulation. For electricity, a declarant-specific addendum is added. The report covers the installation’s direct emissions, the indirect emissions from electricity consumed where the good is in scope for them, and the specific embedded free allocation needed for the adjustment.

• Installation identity and the production processes and routes used for each CBAM good.
• Direct emissions attributed to each good, and indirect emissions from electricity where Annex II of the CBAM Regulation does not exclude them.
• For each purchased precursor: its CN code, specific direct and indirect embedded emissions, the producer’s reporting period, the installation where it was made, its specific embedded free allocation, and any carbon price paid.
• Quantities of each precursor used during the reporting period.
• Any carbon price effectively paid in the country of production, expressed per tonne of good, supported by a carbon price report certified by an independent person.

Sharing through the CBAM Registry or bilaterally

Guidance No. 2 describes two routes. The recommended, currently voluntary route is to register the installation in the operators’ module of the CBAM Registry, upload the verified data once, and share it with every EU declarant that imports the goods. Declarants then see a summary rather than the full report, which protects process data a US producer may consider confidential. The alternative is to send the same report to each buyer separately. Under that route, declarants are obliged to request the complete verification and emissions reports, so the full data leaves the producer’s control. From 2027 the Registry is due to let producers share data with downstream operators that use their goods as precursors.

Verification, Default Values and Why They Matter

In the definitive period, actual emissions used in a CBAM declaration must be verified by a verifier accredited by an EU national accreditation body. Verification is done per installation and includes a site visit, and the verifier issues one verification report per installation that the producer can share with its buyers. Verification companies established outside the EU may apply for accreditation to any national accreditation body offering the service. National accreditation bodies began CBAM accreditation in April 2026, accredited verifiers can register in the CBAM Registry from September 2026, and verification reports can be issued from January 2027. Check the accreditation certificate of any verifier you contract.

The alternative to verified actual data is the default values the Commission sets in Implementing Regulation (EU) 2025/2621, as corrected by Implementing Regulation (EU) 2026/1740 in July 2026. Default values are not specific to any installation, so a US producer running a lower-emission route gets no credit for it unless it supplies verified actual data. For an EU buyer the default value is the fallback when a supplier sends nothing usable, and that fallback determines the certificate cost the buyer attaches to the supplier’s material.

The practical point for a US exporter is timing. Verified 2026 data must exist before the EU buyer files its first annual declaration in 2027. A producer that has not built a monitoring plan and engaged a verifier by early 2027 will have little room to replace default values in its buyers’ first declarations.

CBAM Timeline and Certificate Purchases

The dates below come from the Commission’s CBAM pages and Guidance No. 1. They apply to the EU declarant, but each one sets a deadline for the data a US supplier has to deliver upstream.

The downstream extension proposal

The Commission has also tabled proposal COM(2025) 989, which would extend CBAM to about 180 downstream steel and aluminum products from 2028 and add anti-circumvention measures. The Council’s general approach of June 12, 2026 would add about 200 further goods, and the European Parliament’s environment committee report would take the list to 457 products, with the plenary vote due in September 2026, so the final scope may be wider. It is still a proposal, not law. US exporters of fabricated steel and aluminum products that sit outside Annex I today should track it, because adoption would pull their goods into the same data requests their upstream suppliers face now.

What US Exporters Should Do Now

Start with scope. Map every product shipped to EU customers to its CN code and check it against Annex I, including goods sold through traders and goods that become precursors in an EU-bound product. Then confirm with each EU buyer who the declarant is and whether the buyer expects data through the CBAM Registry or bilaterally.

Next, build the monitoring plan for each installation and line up an accredited verifier. The Commission’s sector guidance for iron and steel, aluminum, fertilizers, cement and hydrogen, published August 14, 2026, sets out the production routes and system boundaries a verifier will test against. Collect precursor data from your own suppliers now, since their emissions roll into yours.

Finally, put the CBAM data in the commercial file alongside origin and export classification. The shipment documents that support import and export freight to the EU should carry the same CN code the emissions report uses, so the buyer can tie each tonne to a verified figure. A consistent trade compliance management record also keeps the CBAM file aligned with US-side obligations such as the Section 232 steel and aluminum regime that governs the same metals on import. For EU buyers building a landed cost calculation, the certificate cost now sits next to freight, duty and VAT, and exporters that supply verified data give them a lower and more predictable number to work with. For the US tariff position on goods moving the other way, see our overview of US tariffs on EU imports.

Frequently Asked Questions