CBAM · embedded emissions in imported goods
The only carbon obligation that looks at what you import, not at your size. Definitive regime from 1 January 2026.
Source: Regolamento (UE) 2023/956; soglia de minimis e calendario dei certificati come da Regolamento (UE) 2025/2083
Who it applies to
EU-established companies importing iron and steel, cement, aluminium, fertilisers, electricity and hydrogen from third countries. Size is irrelevant: the goods and the volume are what matter. Importers below 50 net tonnes a year of CBAM goods are exempt (de minimis threshold, cumulative over the year): the exemption covers most importing SMEs while still capturing around 99% of emissions.
What you must do
- Check the customs codes of imported goods: the obligation depends on the goods, not on your declared sector.
- Monitor cumulative annual volumes against the 50-tonne threshold.
- If above the threshold, obtain authorised declarant status.
- Request embedded-emissions data from non-EU suppliers.
- File the annual declaration and purchase the corresponding certificates.
When
Definitive regime from 1 January 2026. The first declaration, covering 2026 imports, is filed in 2027 together with the surrender of certificates. The exact deadline was amended by Regulation (EU) 2025/2083 and the sources consulted disagree between 31 May and September: check the current calendar with the Italian Customs Agency before the deadline. Member States begin selling certificates in February 2027.
Penalties
Failing to surrender the certificates matching declared emissions carries a penalty of €100 per tonne of uncovered CO₂, aligned with the ETS excess-emissions penalty. The same measure applies to those importing without having obtained declarant authorisation.
What you need at hand
- List of imports by commodity code and volume, cumulative over the year
- Embedded-emissions data provided by non-EU producers
- Supporting customs documentation
The same data, reused
How it connects to the VSME dossier
The data CBAM forces you to request from suppliers is upstream value-chain emissions. In VSME it feeds B3 (energy and greenhouse gas emissions), which in the EFRAG template covers Scope 1, Scope 2 and Scope 3: one data-collection effort, two uses.
organises this data once and makes it reusable for banks, clients and tenders. It does not issue certifications, ratings or assurance.
Informational sheet, not a substitute for professional advice: your situation may depend on legal form, sector, group membership or the compliance model adopted. References verified on 22/07/2026.