With the onset of the CBAM regulation phase starting 1 January 2026, new obligations apply to importers of emission-intensive products. However, a reform introduces noticeable facilitations for smaller businesses.
The European Union aims to reduce its CO₂ emissions by 55% relative to 1990 levels by 2030. A key instrument to achieve this target is the Carbon Border Adjustment Mechanism (CBAM), the CO₂ border adjustment system. It ensures that imported goods are subject to the same CO₂ costs as comparable products within the EU, preventing the outsourcing of emission-intensive production to non-EU countries.
Starting January 2026, the regulation phase begins: importers of certain goods such as steel, aluminium, cement, fertilisers, as well as electricity and hydrogen, will be required to purchase CBAM certificates for the emissions involved in their production. However, the sale of these certificates will only commence on 1 February 2027, retroactively covering imports from the year 2026.
The latest reform introduces significant relief compared to previous requirements:
- Threshold: Only companies importing more than 50 tonnes of CBAM goods annually will be subject to regulations. Smaller importers are exempt from these obligations.
- Deadlines: The annual CBAM declaration must now be submitted by 30 September of the following year (previously 31 May).
- Registration: Only those exceeding the threshold are required to register as "authorised CBAM declarants".
In Germany, the Deutsche Emissionshandelsstelle (DEHSt) is responsible for overseeing the registration and submission of declarations.
More information can be found on the DEHSt website (only available in German).
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Released 09.06.2026