Does CBAM apply to you
Whether CBAM reaches your business is determined by four conditions together: product scope, volume threshold, geographic scope and timing. Only where all four are met does the authorised declarant obligation arise.
Legal basis: Regulation (EU) 2023/956 (as simplified by Reg (EU) 2025/2083) · Status baseline 2026-10-09
01Four applicability conditions
| Condition | Test |
|---|---|
| Product scope | Cement, iron and steel, aluminium, fertilisers, electricity, hydrogen and certain downstream products (such as screws, bolts and aluminium structures). The specific determination is made by CN code against Annex I to the Regulation, not by sector name. |
| Volume threshold | From 2026-01-01 a minimum mass threshold of 50 tonnes per year applies (iron and steel, aluminium, cement and fertilisers are aggregated within the same category of goods); importers whose annual imports exceed 50 tonnes must obtain authorised declarant status. Those below the threshold are in principle exempt, but goods may not be split to circumvent the rules. |
| Geographic scope | Applies to companies in all non-EU countries exporting the relevant products to the 27 EU Member States (Norway, Iceland, Liechtenstein, Switzerland and certain associated territories have separate arrangements). |
| Timing | Transitional period (2023-10 to 2025-12): reporting only; the definitive period starts on 2026-01-01, with CBAM certificates to be purchased and surrendered. |
Scope note
Older material often cites a ‘150-tonne threshold’, which was the transitional-period figure. The definitive period applies the 50 tonnes/year threshold in force from 2026; check against the latest official text.
02Three-step self-check
Answer the three questions below for a preliminary conclusion. This assessment is a deterministic mapping and does not constitute legal advice.
Preliminary conclusion
Please select the three options above.
03Two roles for Chinese companies
The legal responsibility for reporting and payment rests with the ‘authorised declarant’ on the EU side (usually the EU importer or its indirect customs representative). This does not mean the Chinese exporter has nothing to do:
- As producer/exporter: you must provide the EU importer with the product's embedded emissions data, the communication template and (in the definitive period) the verification report.
- As non-EU operator (optional): you may register in the CBAM registry and enter emissions data, valid for 5 years, making it easier to disclose to multiple EU customers without sending sensitive documents individually.
If your EU customer does not report, the missing report will rebound on orders — supply capability is therefore tied to data capability.
04What to do if unsure
Basis: Regulation (EU) 2023/956 Annex I, Article 2; European Commission CBAM official Q&A and importer guidance. This page is a compliance guide; the official text and the competent authority's interpretation prevail. Entries marked "under consideration" or "draft" may change.