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Metals and goods subject to CBAM: importing under the carbon mechanism

Since January 2026, importing steel, aluminium, cement or fertilisers requires an authorised status, emissions data and certificates. The difficulty is almost never reading the regulation: it is getting figures from a supplier who has never calculated them.

Regulatory information verified on 7 August 2026. The CBAM regime is evolving — we revalidate this point on every file.

When this page concerns you

  • You import steel, aluminium, cement, fertilisers, hydrogen or electricity, in any form.
  • You exceed the 50-tonne annual threshold and have not yet applied for authorised CBAM declarant status.
  • Your suppliers do not know what embedded emissions data is, or send you figures that cannot be verified.
  • You do not know whether your processed goods fall under the mechanism — which is often the case for parts assumed to be out of scope.
  • You have to prepare your first annual declaration and do not know which evidence to keep.

What we review

  • The actual scope: which of your tariff codes fall under CBAM, including processed goods further down the chain.
  • Your annual volume against the 50-tonne threshold, and how it is likely to move.
  • Your status: the application for authorised CBAM declarant, processing times, and who owns it in your organisation.
  • The emissions data chain: what your supplier can genuinely produce, and what will have to be replaced by default values.
  • Consistency between your customs declarations and your CBAM declarations — two systems that must tell the same story.

What you receive

  • The list of your affected products, code by code, with the associated volume.
  • A status application file ready to submit, and the calendar of deadlines that concern you.
  • A collection protocol to send to your suppliers, written in their language, stating what they must provide and in what form.

What is included, and what is not

What is included

  • The scope analysis, the status file and the supplier protocol.
  • Coordination with your suppliers and your declarant, in their language.
  • Monitoring of changes to the mechanism and an alert when a deadline concerns you.

What is not included

  • Filing the CBAM declaration: that falls to the authorised declarant appointed by your company.
  • Verifying or certifying emissions data: that is the role of accredited verifiers.
  • Purchasing CBAM certificates and the financial decisions attached to them.

Frame your CBAM exposure

A free 30-minute conversation is enough to know whether you are concerned, and by when.

First conversation free (30 min)