Metals and CBAM: secure your steel and aluminium imports
CBAM ties together your customs codes, your imported volumes, your suppliers' emissions data and your regulatory obligations. CTB Group helps you establish what is actually in scope and build a set-up you can work with.
Regulatory update : content checked on 7 August 2026. The definitive regime is still evolving ; the applicable rules are revalidated for each file.
Is your company concerned?
Products
You import iron, steel, aluminium or certain processed metal products whose codes may fall under CBAM.
Volumes
Your cumulative annual volumes approach or exceed the applicable regulatory threshold.
Suppliers
Your suppliers do not yet hold emissions data that is sufficiently documented or verifiable.
Organisation
Responsibilities between customs, purchasing, finance, ESG, the declarant and suppliers are not clearly allocated.
What we review
Tariff scope
The nomenclature codes, the goods covered, the processed products, the countries of origin and the suppliers concerned.
Quantitative exposure
Net imported mass, cumulative volumes, history and their foreseeable trend against the applicable threshold.
Emissions data
The availability, format and traceability of actual data, together with the conditions for using the default values provided for by the regulation.
Governance
Authorised CBAM declarant status, internal responsibilities, the supporting evidence to keep and the consistency between customs and CBAM data.
What you receive
- A mapping of the codes, products and suppliers concerned.
- A table of volumes and of your exposure to the mechanism.
- A roadmap towards authorised CBAM declarant status.
- A calendar of deadlines and of the evidence to keep.
- A data collection protocol in the working language agreed with your suppliers.
- A clear matrix of roles and responsibilities.
A directly usable result
You know which flows to handle first, which data to request, who owns each action and which deadlines to prepare for.
The deadlines to prepare for
Definitive regime
Monitoring of imports, of status, of codes and of the emissions data chain.
Preparation
Supplier data collection, consistency checks and organisation of supporting evidence.
First declaration
Expected deadline for the first annual declaration covering 2026 imports.
What is included, and what is not
Included in the agreed engagement
- Analysis of the scope and of the customs data available.
- Preparation of the working file relating to the status.
- Collection protocol and operational coordination.
- Calendar of obligations and regulatory monitoring for the agreed duration of the engagement.
Not included
- The decision of the competent authority or the granting of the status.
- Verification and certification of emissions by an accredited verifier.
- The purchase of certificates and the associated financial decisions.
- Lodging on the client's behalf, unless expressly mandated and agreed.
The 50-tonne threshold, and the trap it conceals
Since the move to the definitive regime, a so-called de minimis exemption releases operators from CBAM obligations where their cumulative imports remain below 50 tonnes per calendar year. It replaced the former threshold based on consignment value. The Commission estimates it exempts around nine importers in ten, while still covering almost all of the emissions concerned.
Many companies conclude from this that they are not affected. That is precisely where the real risk lies.
The threshold is cumulative, not per consignment
It is assessed on the total net mass of all your imports of covered goods over the year, across every supplier and every product. A company importing small quantities of steel on a regular basis can cross it without noticing.
Crossing it pulls in the whole year
Once the threshold is exceeded, the obligations apply to all volumes imported during the year, not only to the tonnes above it. A company discovering the overrun in November must reconstruct emissions data it has not been collecting since January.
Two products with no exemption
The 50-tonne exemption covers cement, fertilisers, pig iron, iron, steel and aluminium. Electricity and hydrogen are excluded: the obligations apply whatever the volume imported.
Staying below the threshold is therefore not a settled position: it is one to monitor. And the exemption itself is declared at customs. That is exactly what we put in place: a running total that alerts you before you cross, while there is still time to organise collection from suppliers.
Frequently asked questions
My supplier refuses to share its emissions data. What can I do?
This is the most common difficulty, and it is rarely a refusal on principle: the producer simply does not hold the data in the expected form. What works is to put the request in their working language, to state the exact scope of the installations and to offer a collection template rather than an open questionnaire. Where actual data stays out of reach, the regulation provides fallback methods, but they come at a cost, and it is better to know that cost before shipment.
I am under 50 tonnes. Do I really have anything to do?
Yes: keep track of your cumulative total and declare your exemption to customs. The threshold is assessed over the full calendar year and on total net mass. As long as you stay below it, you have no authorisation to apply for, no certificates to buy and no declaration to lodge. But the exemption is not a permanent status: it is a position that has to be checked continuously.
Who declares: me or my freight forwarder?
The obligations fall on the importer established in the Union, or on its indirect customs representative where there is one. The point to settle is contractual: an indirect representative declaring on your behalf takes on obligations of its own, and that must be put in writing. We map who carries what in your set-up, but we do not lodge the declaration: we are not a declarant.
Payment is only due in 2027. Can I wait?
The gap is real, but it is misleading. Certificates are surrendered in 2027 for goods imported in 2026: the liability is building up now, on emissions that have to be documented as the imports happen. A company that starts collecting in 2027 will have to reconstruct a full year of data from suppliers who have no reason to hurry. Provisioning the cost is an accounting decision; organising the collection is an operational one, and it cannot wait.
How do I know whether my products are covered?
By the nomenclature code, not by the commercial description. Scope is judged product by product, and two references sitting next to each other in a catalogue can fall under different codes. That is the first task of the diagnostic: going through your purchasing portfolio and drawing up the exact list of the references concerned, with the associated volumes.
Do you know exactly which products and volumes are concerned?
In 30 minutes we can frame your situation, identify the first checks required and determine the right level of support.
Since 1 January 2026, importing these goods requires authorised CBAM declarant status.