[{"data":1,"prerenderedAt":3026},["ShallowReactive",2],{"blog-index":3},[4,248,670,1155,1429,1702,1962,2210,2516,2737,2857],{"id":5,"title":6,"body":7,"date":233,"description":234,"extension":235,"hero":236,"heroAlt":236,"keywords":237,"meta":238,"navigation":239,"path":240,"readingMinutes":241,"seo":242,"stem":243,"tags":244,"__hash__":247},"blog\u002Fblog\u002Fcbam-cscf-100-percent-published.md","The CBAM factor nobody could look up is now 100 %",{"type":8,"value":9,"toc":224},"minimark",[10,19,26,29,34,37,48,63,70,74,77,86,97,104,108,115,118,124,139,143,146,149,156,159,170,174,181,184,188,216,219],[11,12,13,14,18],"p",{},"For most of this year, one of the inputs to the CBAM calculation could not be looked up anywhere. Not\nbecause it was hard to find — because it did not exist yet. The ",[15,16,17],"strong",{},"cross-sectoral correction factor",",\nthe CSCF, sits in the formula that decides how much of your embedded emissions is treated as free of\ncharge, and for the allocation period beginning 1 January 2026 it was simply unset.",[11,20,21,22,25],{},"It is set now. ",[15,23,24],{},"100 %, for every year from 2026 to 2030"," (Article 1 of Implementing Decision (EU)\n2026\u002F1862 of 23 July 2026, published in the Official Journal on 24 July 2026).",[11,27,28],{},"That is the short version, and for most declarants it is good news of the dullest kind: the number\npeople assumed turned out to be the number that was adopted. The part worth six minutes is what it\ndoes — and does not do — to figures that were already calculated.",[30,31,33],"h2",{"id":32},"where-the-factor-sits","Where the factor sits",[11,35,36],{},"Under the definitive regime, the free-allocation adjustment for a good is:",[38,39,44],"pre",{"className":40,"code":42,"language":43},[41],"language-text","SEFA = CBAM factor × CSCF × benchmark\n","text",[45,46,42],"code",{"__ignoreMap":47},"",[11,49,50,51,54,55,58,59,62],{},"Three terms, and only the middle one was missing. The ",[15,52,53],{},"CBAM factor"," is the share still allocated\nfree in a given year and steps down on a schedule written into the law — 97.5 % in 2026, 95 % in\n2027, 90 % in 2028, 77.5 % in 2029, 51.5 % in 2030 (Article 10a(1a) of Directive 2003\u002F87\u002FEC). The\n",[15,56,57],{},"benchmark"," is the goods-specific figure published in the annex to Implementing Regulation (EU)\n2025\u002F2620. The ",[15,60,61],{},"CSCF"," is a uniform factor that exists to keep\nthe total of all free allocation inside the emissions-trading cap: if the sum of what installations\nare entitled to exceeds the ceiling, everyone's allocation is scaled down by the same percentage\n(Article 10a(5) and (5a) of Directive 2003\u002F87\u002FEC).",[11,64,65,66,69],{},"That is the whole mechanism, and it explains why the factor is so easy to miss. ",[15,67,68],{},"It is not a CBAM\ninstrument."," It is adopted under Article 14(6) of Delegated Regulation (EU) 2019\u002F331, in the\nemissions-trading file, on the schedule of the free-allocation cycle — and it lands in the CBAM\nformula from the side. A declarant watching the CBAM acts for the numbers they need would not have\nseen it coming, and would not see it change.",[30,71,73],{"id":72},"what-was-decided-and-why","What was decided, and why",[11,75,76],{},"The decision is short. Article 1 sets the factor for the whole allocation period at once:",[78,79,80],"blockquote",{},[11,81,82],{},[83,84,85],"em",{},"\"For each year in the allocation period 2026 to 2030, the uniform cross-sectoral correction factor\nfor the adjustment of free allocations of emission allowances in accordance with Article 10a(5) and\n(5a) of Directive 2003\u002F87\u002FEC shall be 100 %.\"",[11,87,88,89,92,93,96],{},"The reasoning is in the recitals, and it is arithmetic rather than policy. Of the maximum amount\navailable for free allocation in 2021–2025, ",[15,90,91],{},"125,586,948 allowances went unused",", alongside the\nentire 3 % reserve for that period (recital 8). Against that headroom, the Commission puts the total\ndraw needed across 2021–2030 at ",[15,94,95],{},"289,226,630"," allowances from the reserve (recital 9). The\nentitlement fits inside the ceiling, so nothing has to be scaled down — the factor is 100 % and the\nterm is neutral.",[11,98,99,100,103],{},"Two things are worth noting beside it. The same factor was ",[15,101,102],{},"100 % for 2021–2025"," (Implementing\nDecision (EU) 2021\u002F927), so the adopted value continues an unbroken line rather than breaking one.\nAnd it is not to be confused with Decision (EU) 2026\u002F1312 of 15 June 2026, which approved the\nnational implementation measures — the installation lists — five weeks earlier and sets no factor at\nall. If you went looking in June and came back empty-handed, that is probably what you found.",[30,105,107],{"id":106},"what-100-means-in-the-arithmetic","What 100 % means in the arithmetic",[11,109,110,111,114],{},"It means the middle term drops out. ",[45,112,113],{},"SEFA = CBAM factor × benchmark",", and the figure you get is the\nfigure you would have got by assuming 1.0.",[11,116,117],{},"A worked line, using a cement consignment of the kind that shows up in every second CBAM file — grey\nclinker under CN 2523 10 00, benchmark 0.6660 tCO₂\u002Ft, imported in 2026:",[38,119,122],{"className":120,"code":121,"language":43},[41],"SEFA = 0.975 × 1.000 × 0.6660 = 0.64935 tCO₂\u002Ft\n",[45,123,121],{"__ignoreMap":47},[11,125,126,127,130,131,134,135,138],{},"Now the counterfactual, because it shows how much was riding on an unpublished number. Had the factor\ncome in at 90 %, the same line would read ",[45,128,129],{},"0.975 × 0.900 × 0.6660 = 0.584415"," — a free allocation\nlower by 0.064935 tCO₂ per tonne. On a 512-tonne consignment that is ",[15,132,133],{},"33 certificates",", about\n",[15,136,137],{},"€2,500"," at the Q2 2026 certificate price of €75.28. One consignment, one commodity, one\npercentage point set in a decision most CBAM declarants never read.",[30,140,142],{"id":141},"the-number-is-right-the-status-is-not","The number is right. The status is not.",[11,144,145],{},"Here is the part that catches tidy operations.",[11,147,148],{},"If you computed a 2026 obligation before 24 July 2026, you used an assumption. The decision does not\nretroactively turn that into a calculation — it produces the same digits, which is a different thing.\nEvery figure computed under the assumption is now confirmable, and until somebody confirms it, it is\na figure whose basis is a guess that happened to be correct.",[11,150,151,152,155],{},"That distinction has a practical edge, because the failure mode is invisible. A recomputed figure and\nan assumed figure are ",[15,153,154],{},"identical to the last decimal",". Nothing in the output flags which is which.\nIf your process marks provisional figures — and it should — then those marks are the only thing\nstanding between \"we checked\" and \"we were lucky\", and they do not clear themselves when the act is\npublished. Somebody has to recompute against the adopted value and re-date the result.",[11,157,158],{},"In our own system that is deliberate: an assessment carries the provisional flag it was stored with,\nthe declaration export stays locked while any figure on it is provisional, and publishing the\ndecision does not silently unlock anything. The figures do not change. Their standing does, and only\nonce they have been run again.",[11,160,161,162,165,166,169],{},"Anyone who assumed something ",[83,163,164],{},"other"," than 1.0 has the opposite problem and a bigger one. A factor\nwhose entire purpose is to scale allocations down invites a cautious guess below 100 %, and a\ncautious guess is the wrong kind here: it understates the free allocation and therefore\n",[15,167,168],{},"overstates"," the certificate obligation. That is the error that costs money rather than the one\nthat costs a penalty, and nobody is going to write to you about it.",[30,171,173],{"id":172},"one-more-thing-and-it-is-genuinely-useful","One more thing, and it is genuinely useful",[11,175,176,177,180],{},"The decision covers ",[15,178,179],{},"2026 to 2030 in a single article",". That is five reporting years in which this\nparticular input does not move, does not need an annual lookup, and does not belong in the list of\nthings to re-check each January. The next time it is open is the allocation period starting in 2031.",[11,182,183],{},"For a regime where almost everything else is annual — the CBAM factor steps every year, the benchmark\nannex is revised, the certificate price moves quarterly in 2026 and weekly from 2027 — one input that\nis fixed for five years is worth writing down as fixed.",[30,185,187],{"id":186},"what-to-check-this-week","What to check this week",[189,190,191,198,204,210],"ol",{},[192,193,194,197],"li",{},[15,195,196],{},"Find out which CSCF your figures used."," Not which one your provider intended — which one is in\nthe stored calculation. If the answer is \"1.0 by assumption\", you are fine numerically and owe\nyourself a recomputation for the record.",[192,199,200,203],{},[15,201,202],{},"Recompute anything calculated before 24 July 2026"," and re-date it, rather than reasoning that\nthe result would be unchanged. It would be. That is not the point of the exercise.",[192,205,206,209],{},[15,207,208],{},"If any figure came in with a factor below 100 %, redo it."," It overstates your obligation, and\nnobody will send you a correction for paying too much.",[192,211,212,215],{},[15,213,214],{},"Take this one off your annual list"," until 2031, and put the source on it: the Official Journal\nentry, not a summary. One practical note for anyone automating that check — EUR-Lex answers\nscripted requests for this document with an empty response, so the text has to be read by hand.",[217,218],"hr",{},[11,220,221],{},[83,222,223],{},"This article explains the rules as we read them; it is not legal advice. The factor is set by\nArticle 1 of Implementing Decision (EU) 2026\u002F1862 of 23 July 2026 (OJ L, 24 July 2026), adopted under\nArticle 14(6) of Delegated Regulation (EU) 2019\u002F331; the free-allocation mechanism in Article 10a(5)\nand (5a) of Directive 2003\u002F87\u002FEC; the CBAM free-allocation adjustment and its benchmarks in\nImplementing Regulation (EU) 2025\u002F2620; the preceding period's factor in Implementing Decision (EU)\n2021\u002F927. The recital figures are quoted from the decision itself. Verify your own position with your\ncustoms agent or the competent authority in your member state — in Germany, the DEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":226},2,[227,228,229,230,231,232],{"id":32,"depth":225,"text":33},{"id":72,"depth":225,"text":73},{"id":106,"depth":225,"text":107},{"id":141,"depth":225,"text":142},{"id":172,"depth":225,"text":173},{"id":186,"depth":225,"text":187},"2026-09-20","One input in the CBAM free-allocation formula could not be looked up for most of 2026: the cross-sectoral correction factor. It was set on 23 July 2026 at 100 % for every year to 2030 — and it arrived as an emissions-trading decision, not a CBAM one. If you assumed 1.0, your number is right. Its status still is not.","md",null,"CBAM cross-sectoral correction factor, CSCF 2026, Implementing Decision (EU) 2026\u002F1862, CBAM free allocation SEFA, CBAM factor 97.5% 2026, CBAM Durchführungsbeschluss 2026\u002F1862, CSCF 100 percent 2026 2030",{},true,"\u002Fblog\u002Fcbam-cscf-100-percent-published",6,{"title":6,"description":234},"blog\u002Fcbam-cscf-100-percent-published",[245,246],"calculation","compliance","Z5zB0sFhCpqbUDWXAqmpB32SgyZEh97D85AcRArVp5M",{"id":249,"title":250,"body":251,"date":661,"description":662,"extension":235,"hero":236,"heroAlt":236,"keywords":663,"meta":664,"navigation":239,"path":665,"readingMinutes":241,"seo":666,"stem":667,"tags":668,"__hash__":669},"blog\u002Fblog\u002Fcbam-mark-up-do-not-recompute.md","Never recompute the CBAM mark-up. 2026 will not tell you why.",{"type":8,"value":252,"toc":653},[253,260,263,270,274,277,437,440,443,447,462,465,568,571,577,581,584,591,594,598,601,604,611,615,621,632,635,637,643,646,648],[11,254,255,256,259],{},"The EU default values come with a penalty built in. If you use them instead of verified supplier\ndata, the published figure is your emissions plus a statutory mark-up — and the mark-up rises with\nthe year, not with the material: ",[15,257,258],{},"+10 % in 2026, +20 % in 2027, +30 % from 2028"," (Annex I of\nImplementing Regulation (EU) 2025\u002F2621). Fertiliser is the one exception, flat at +1 % in all three\nyears.",[11,261,262],{},"So the annex publishes two numbers per row: the raw value, and the marked-up value for each of the\nthree year columns. Which invites an obvious shortcut. You have the raw figure, you know the year,\nyou multiply.",[11,264,265,266,269],{},"Do not. And the reason it is worth a whole article is that ",[15,267,268],{},"in 2026 the shortcut works perfectly"," —\nso it will not warn you.",[30,271,273],{"id":272},"what-is-actually-in-the-table","What is actually in the table",[11,275,276],{},"We load the whole annex into our own store: 32,790 rows, 10,930 per year, across five sectors. Taking\nthe ratio of published to raw on every row gives this:",[278,279,280,299],"table",{},[281,282,283],"thead",{},[284,285,286,290,293,296],"tr",{},[287,288,289],"th",{},"Year",[287,291,292],{},"Ratio",[287,294,295],{},"Rows",[287,297,298],{},"Sector",[300,301,302,317,330,343,354,366,378,397,408,420],"tbody",{},[284,303,304,308,311,314],{},[305,306,307],"td",{},"2026",[305,309,310],{},"×1.0100",[305,312,313],{},"2,416",[305,315,316],{},"fertiliser",[284,318,319,321,324,327],{},[305,320,307],{},[305,322,323],{},"×1.1000",[305,325,326],{},"8,512",[305,328,329],{},"aluminium, cement, hydrogen, iron & steel",[284,331,332,334,337,340],{},[305,333,307],{},[305,335,336],{},"×1.0999",[305,338,339],{},"1",[305,341,342],{},"iron & steel",[284,344,345,348,350,352],{},[305,346,347],{},"2027",[305,349,310],{},[305,351,313],{},[305,353,316],{},[284,355,356,358,361,364],{},[305,357,347],{},[305,359,360],{},"×1.2000",[305,362,363],{},"8,502",[305,365,329],{},[284,367,368,370,373,376],{},[305,369,347],{},[305,371,372],{},"×1.2001",[305,374,375],{},"7",[305,377,342],{},[284,379,380,382,387,392],{},[305,381,347],{},[305,383,384],{},[15,385,386],{},"×1.2100",[305,388,389],{},[15,390,391],{},"5",[305,393,394],{},[15,395,396],{},"cement",[284,398,399,402,404,406],{},[305,400,401],{},"2028",[305,403,310],{},[305,405,313],{},[305,407,316],{},[284,409,410,412,415,418],{},[305,411,401],{},[305,413,414],{},"×1.3000",[305,416,417],{},"8,509",[305,419,329],{},[284,421,422,424,429,433],{},[305,423,401],{},[305,425,426],{},[15,427,428],{},"×1.3310",[305,430,431],{},[15,432,391],{},[305,434,435],{},[15,436,396],{},[11,438,439],{},"Look at 2026 on its own and the rule holds everywhere. One row is off by a ten-thousandth, which is\nrounding. Nothing suggests the shortcut is unsafe.",[11,441,442],{},"Now look at 2027 and 2028.",[30,444,446],{"id":445},"five-rows-where-the-act-compounds-instead","Five rows where the act compounds instead",[11,448,449,450,453,454,457,458,461],{},"1.10, ",[15,451,452],{},"1.21",", ",[15,455,456],{},"1.331",". Those are not arbitrary. They are 1.1¹, 1.1², 1.1³ — the mark-up applied\n",[83,459,460],{},"again each year"," rather than stepped 10 \u002F 20 \u002F 30.",[11,463,464],{},"It affects five (origin, CN) pairs, all cement, all from two countries:",[278,466,467,486],{},[281,468,469],{},[284,470,471,474,477,480,483],{},[287,472,473],{},"Origin",[287,475,476],{},"CN",[287,478,479],{},"Raw",[287,481,482],{},"2027 published",[287,484,485],{},"2028 published",[300,487,488,505,521,537,553],{},[284,489,490,493,496,499,502],{},[305,491,492],{},"Angola",[305,494,495],{},"2523 10 00",[305,497,498],{},"1.2600",[305,500,501],{},"1.5246",[305,503,504],{},"1.6771",[284,506,507,509,512,515,518],{},[305,508,492],{},[305,510,511],{},"2523 29 00",[305,513,514],{},"1.2700",[305,516,517],{},"1.5367",[305,519,520],{},"1.6904",[284,522,523,525,528,531,534],{},[305,524,492],{},[305,526,527],{},"2523 90 00",[305,529,530],{},"1.2200",[305,532,533],{},"1.4762",[305,535,536],{},"1.6238",[284,538,539,542,544,547,550],{},[305,540,541],{},"Argentina",[305,543,495],{},[305,545,546],{},"0.9000",[305,548,549],{},"1.0890",[305,551,552],{},"1.1979",[284,554,555,557,559,562,565],{},[305,556,541],{},[305,558,511],{},[305,560,561],{},"0.9200",[305,563,564],{},"1.1132",[305,566,567],{},"1.2245",[11,569,570],{},"Check the first line yourself: 1.26 × 1.21 = 1.5246, and 1.26 × 1.331 = 1.6771. The linear rule would\nhave given 1.512 and 1.638.",[11,572,573,576],{},[15,574,575],{},"And in 2026 these same five rows sit at exactly ×1.1000"," — indistinguishable from every other row\nin the table. The divergence does not exist yet. Whatever you build this year to check your figures\nwill pass, and then quietly stop being right on 1 January 2027.",[30,578,580],{"id":579},"what-it-costs","What it costs",[11,582,583],{},"The gap on Angolan clinker is 0.0126 tCO₂\u002Ft in 2027 and 0.0391 in 2028 — 0.8 % and 2.3 % of the\npublished value.",[11,585,586,587,590],{},"The free-allocation subtraction does not move when SEE does, so a shortfall in SEE carries straight\nthrough to the certificate count. On a 1,000 t consignment of CN 2523 10 00 from Angola in 2028, the\nlinear shortcut understates the obligation by about ",[15,588,589],{},"39 certificates"," — roughly €2,900 at the Q2\n2026 certificate price of €75.28. Article 26 penalises under-surrender at three to five times the\ncertificate price, so the exposure is a multiple of that, not the figure itself.",[11,592,593],{},"That is one origin and one commodity. Small. The point is not the size of this particular gap — it is\nthat a method which reproduces the published table exactly, on ten thousand rows, in the year you are\nimporting, is still the wrong method.",[30,595,597],{"id":596},"eight-rows-that-never-land-on-the-factor-at-all","Eight rows that never land on the factor at all",[11,599,600],{},"There is a second, smaller finding in that ratio table, and it matters for a different reason.",[11,602,603],{},"One 2026 row (Angola, CN 2601 12 00) comes out at ×1.0999: raw 0.6166, published 0.6782, where the\nexact product is 0.67826. And seven 2027 rows — all Thailand, all iron and steel, all sharing the raw\nvalue 1.4396 — come out at ×1.2001: published 1.7276 against an exact 1.72752.",[11,605,606,607,610],{},"Those are four-decimal rounding in the published table, nothing more. But they are worth noticing,\nbecause they tell you something about the column: ",[15,608,609],{},"it was authored, not derived."," The act publishes\na figure. It does not publish a recipe you are meant to run. Recompute it and you will sometimes get\na number the act does not contain — usually in the fourth decimal, occasionally, as above, in the\nfirst.",[30,612,614],{"id":613},"two-numbers-and-you-need-both","Two numbers, and you need both",[11,616,617,618],{},"The practical rule is short: ",[15,619,620],{},"read the published column for the year, verbatim.",[11,622,623,624,627,628,631],{},"But do not throw the raw value away either, and this is the part that catches people who tidy up\ntheir data model. Article 22(2) of Regulation (EU) 2023\u002F956 computes the ",[15,625,626],{},"quarterly holding\nobligation"," — the 50 % of your year-to-date liability you must hold in certificates at each\nquarter-end — on the value ",[83,629,630],{},"without"," the mark-up.",[11,633,634],{},"So the two figures serve two different purposes, in two different places, and neither can be derived\nfrom the other with confidence. Store both. We do, in the same row, precisely because storing one and\ncomputing the other guarantees a wrong number somewhere.",[30,636,187],{"id":186},[11,638,639,640],{},"If you or a provider computes CBAM figures from the default values, ask one question: ",[15,641,642],{},"is the\nyear-column value read from the act, or multiplied out?",[11,644,645],{},"If the answer is \"multiplied out\", it is producing correct numbers today and will produce wrong ones\nfor cement from Angola and Argentina in fifteen months — with nothing in this year's output to\nsuggest it. And ask the same question about the quarterly holding figure, from the other direction:\nif it uses the marked-up value, it is overstating what you must hold.",[217,647],{},[11,649,650],{},[83,651,652],{},"This article explains the rules as we read them; it is not legal advice. The default values, their\nyear columns and the mark-up are set out in Annex I of Implementing Regulation (EU) 2025\u002F2621; the\nquarterly holding obligation in Article 22(2) of Regulation (EU) 2023\u002F956 as amended by Regulation\n(EU) 2025\u002F2083; the penalty regime in Article 26 of the same. The row counts and ratios above are\nfrom our own load of the published annex and are reproducible from it. Verify your own position with\nyour customs agent or the competent authority in your member state — in Germany, the DEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":654},[655,656,657,658,659,660],{"id":272,"depth":225,"text":273},{"id":445,"depth":225,"text":446},{"id":579,"depth":225,"text":580},{"id":596,"depth":225,"text":597},{"id":613,"depth":225,"text":614},{"id":186,"depth":225,"text":187},"2026-09-10","The default values carry a statutory mark-up that rises with the year, and it is tempting to apply it yourself. In 2026 that gives the right answer on every row. From 2027 it stops — five cement rows compound instead, and eight steel rows never land on the factor at all. Read the published column.","CBAM default values mark-up, CBAM Aufschlag Standardwerte, IR 2025\u002F2621 Annex I, CBAM 2027 mark-up 20%, CBAM cement Angola Argentina, Art 22(2) CBAM quarterly holding, CBAM SEE calculation",{},"\u002Fblog\u002Fcbam-mark-up-do-not-recompute",{"title":250,"description":662},"blog\u002Fcbam-mark-up-do-not-recompute",[245,246],"TzmkDwADHKpGaDuU5sIHMb0aiynY3NSBwDXyVZzaLRE",{"id":671,"title":672,"body":673,"date":1145,"description":1146,"extension":235,"hero":236,"heroAlt":236,"keywords":1147,"meta":1148,"navigation":239,"path":1149,"readingMinutes":1150,"seo":1151,"stem":1152,"tags":1153,"__hash__":1154},"blog\u002Fblog\u002Fcbam-two-acts-that-contradict-each-other.md","Fifteen steel codes where we cannot reconcile the two CBAM acts",{"type":8,"value":674,"toc":1137},[675,678,681,684,688,695,756,775,778,782,789,795,798,835,838,849,859,863,866,986,989,993,1000,1053,1056,1059,1066,1073,1077,1080,1083,1102,1109,1116,1120,1127,1130,1132],[11,676,677],{},"Two implementing regulations sit underneath every CBAM steel calculation. One gives you the default\nemissions to use when you have no verified supplier data. The other gives you the free-allocation\nbenchmark you subtract from it. Both are published, both are in force, and for most goods they line\nup.",[11,679,680],{},"For fifteen CN codes we cannot get them to line up. Not \"the data is unclear\" — the route one act\nnames for the good is not among the routes the other publishes a benchmark for. We have not found a\nreading of the two annexes that yields a figure.",[11,682,683],{},"We did not find this by reading. We found it by running every declarable combination through our own\ncalculation and looking at what refused to resolve. What follows is that derivation, in full, so you\ncan check it — and correct us if there is a reading we missed.",[30,685,687],{"id":686},"the-letters-and-what-they-actually-mean","The letters, and what they actually mean",[11,689,690,691,694],{},"Both acts describe production routes with single letters in brackets. Most summaries treat these as\nif they were categories of goods. They are not. The Annex I legend encodes ",[15,692,693],{},"grade × route",":",[278,696,697,707],{},[281,698,699],{},[284,700,701,704],{},[287,702,703],{},"Marker",[287,705,706],{},"Meaning",[300,708,709,717,728,740,748],{},[284,710,711,714],{},[305,712,713],{},"(A) \u002F (B)",[305,715,716],{},"grey \u002F white cement",[284,718,719,722],{},[305,720,721],{},"(C) \u002F (D) \u002F (E)",[305,723,724,727],{},[15,725,726],{},"carbon"," steel via BF\u002FBOF, DRI\u002FEAF, Scrap\u002FEAF",[284,729,730,733],{},[305,731,732],{},"(F) \u002F (G) \u002F (H)",[305,734,735,736,739],{},"the ",[15,737,738],{},"same three routes"," for low-alloy steel",[284,741,742,745],{},[305,743,744],{},"(J)",[305,746,747],{},"high-alloy steel (EAF)",[284,749,750,753],{},[305,751,752],{},"(K) \u002F (L)",[305,754,755],{},"primary \u002F secondary aluminium",[11,757,758,759,762,763,766,767,770,771,774],{},"Read the second axis carefully, because it is the one that causes the problem. ",[45,760,761],{},"BF\u002FBOF"," is ",[15,764,765],{},"(C)"," for\ncarbon steel and ",[15,768,769],{},"(F)"," for low-alloy steel. The letter does not tell you the furnace alone — it\ntells you the furnace ",[83,772,773],{},"and"," the grade.",[11,776,777],{},"And the grade is a composition fact. Implementing Regulation (EU) 2025\u002F2620, point 5.2.3 draws the\nline at 8 % alloying elements. Your CN code does not carry that. Your customs declaration does not\ncarry it. It lives in the mill certificate, if you have one.",[30,779,781],{"id":780},"where-the-two-do-not-meet","Where the two do not meet",[11,783,784,785,788],{},"Take CN ",[15,786,787],{},"7225 19 90"," — flat-rolled products of other alloy steel, of silicon-electrical\nsteel, other than grain-oriented, other than hot-rolled.",[11,790,791,792,794],{},"Implementing Regulation (EU) 2025\u002F2621, the default-values annex, assigns it ",[15,793,769],{},": low-alloy,\nBF\u002FBOF route.",[11,796,797],{},"Implementing Regulation (EU) 2025\u002F2620, the benchmark annex, publishes free-allocation benchmarks for\nthat code as:",[278,799,800,810],{},[281,801,802],{},[284,803,804,807],{},[287,805,806],{},"Route",[287,808,809],{},"Benchmark (tCO₂\u002Ft)",[300,811,812,819,827],{},[284,813,814,816],{},[305,815,765],{},[305,817,818],{},"1.488",[284,820,821,824],{},[305,822,823],{},"(D)",[305,825,826],{},"0.563",[284,828,829,832],{},[305,830,831],{},"(E)",[305,833,834],{},"0.138",[11,836,837],{},"There is no (F). The defaults act tells you which route to assume; the benchmark act publishes no\nvalue for that route. The two vocabularies do not meet.",[11,839,840,841,844,845,848],{},"This is not a rounding question. ",[45,842,843],{},"SEFA = CBAM_y × CSCF_y × BM_g"," needs a ",[45,846,847],{},"BM_g",", and for this code\nunder that marker the benchmark annex publishes none. If there is a reading of the two annexes that\nsupplies one, we have not found it — and we would genuinely rather be told than keep blocking the\ngood.",[11,850,851,852,855,856,858],{},"The neighbouring line makes it stranger: ",[15,853,854],{},"7225 19 10",", the hot-rolled sibling one row above,\ncarries ",[15,857,765],{}," — a route the benchmark table does publish. Same subheading, same annex, one code\nresolves and the next does not.",[30,860,862],{"id":861},"the-fifteen-codes","The fifteen codes",[11,864,865],{},"Eighteen (code, marker) pairs across fifteen distinct CN codes, all of them iron and steel — five\nunder chapter 72, ten under chapter 73:",[278,867,868,878],{},[281,869,870],{},[284,871,872,875],{},[287,873,874],{},"CN code",[287,876,877],{},"Marker named by the defaults act, unpublished in the benchmark act",[300,879,880,888,895,902,909,916,923,930,937,944,951,958,965,972,979],{},[284,881,882,885],{},[305,883,884],{},"7205 21 00",[305,886,887],{},"(C), (E)",[284,889,890,892],{},[305,891,787],{},[305,893,894],{},"(F), (H)",[284,896,897,900],{},[305,898,899],{},"7226 19 80",[305,901,894],{},[284,903,904,907],{},[305,905,906],{},"7228 30 41",[305,908,769],{},[284,910,911,914],{},[305,912,913],{},"7228 30 49",[305,915,769],{},[284,917,918,921],{},[305,919,920],{},"7304 31 20",[305,922,769],{},[284,924,925,928],{},[305,926,927],{},"7304 31 80",[305,929,769],{},[284,931,932,935],{},[305,933,934],{},"7304 51 10",[305,936,765],{},[284,938,939,942],{},[305,940,941],{},"7304 51 81",[305,943,765],{},[284,945,946,949],{},[305,947,948],{},"7304 51 89",[305,950,765],{},[284,952,953,956],{},[305,954,955],{},"7304 59 82",[305,957,765],{},[284,959,960,963],{},[305,961,962],{},"7304 59 83",[305,964,765],{},[284,966,967,970],{},[305,968,969],{},"7304 59 89",[305,971,765],{},[284,973,974,977],{},[305,975,976],{},"7306 50 21",[305,978,765],{},[284,980,981,984],{},[305,982,983],{},"7306 50 80",[305,985,765],{},[11,987,988],{},"If you import any of these, this is worth checking against your own figures — not because your data\nis wrong, but because any figure you have been given for them rests on somebody having chosen a route.\nAsk which one, and on what basis.",[30,990,992],{"id":991},"how-we-know","How we know",[11,994,995,996,999],{},"We ran the full grid: ",[15,997,998],{},"119 origins × 570 CN codes"," for import year 2026 — 67,830 combinations —\nthrough the same resolution chain our product uses in production, for a document that states no\nproduction route. That is the realistic case: a customs declaration does not tell you whether the\nsteel came out of a blast furnace or an arc furnace.",[278,1001,1002,1012],{},[281,1003,1004],{},[284,1005,1006,1009],{},[287,1007,1008],{},"Outcome",[287,1010,1011],{},"Count",[300,1013,1014,1022,1030,1038,1046],{},[284,1015,1016,1019],{},[305,1017,1018],{},"Resolved to a figure",[305,1020,1021],{},"66,820 (98.5 %)",[284,1023,1024,1027],{},[305,1025,1026],{},"Blocked — route not resolvable",[305,1028,1029],{},"912",[284,1031,1032,1035],{},[305,1033,1034],{},"Blocked — more than one candidate default row",[305,1036,1037],{},"98",[284,1039,1040,1043],{},[305,1041,1042],{},"Blocked — no default value at all",[305,1044,1045],{},"0",[284,1047,1048,1051],{},[305,1049,1050],{},"Blocked — benchmark missing for a named route",[305,1052,1045],{},[11,1054,1055],{},"The two zero rows are guards on our own data load, not a verdict on the acts — read them that way and\nthey would seem to say the contradiction does not exist. It does; it is caught by a different check,\ndescribed below.",[11,1057,1058],{},"The last two lines are the ones that matter for trust in the data load. Zero missing default values\nmeans the annex is fully covered — no published benchmark is sitting there without a default value\nbehind it. Zero missing benchmarks means the same in the other direction, for the combinations a real\nimport produces.",[11,1060,1061,1062,1065],{},"The eighteen conflicts are caught one level up, by a separate check that walks every ",[83,1063,1064],{},"named"," marker in\nthe annex rather than every import combination. That check does not tolerate a percentage: it asserts\nthe exact list, so a nineteenth conflict — or the disappearance of one, should the Commission amend an\nannex — fails the build rather than passing quietly.",[11,1067,1068,1069,1072],{},"The other 912 are a different, milder shape: the annex marks a route for most origins of a code and\nleaves it unmarked for a few. CN ",[15,1070,1071],{},"7207 19 12"," is the pattern — (C) for 27 origins, (E) for 5, and\nnothing at all for North Macedonia, against a benchmark published per route (C 1.364 \u002F D 0.475 \u002F\nE 0.066). The act does not say which applies. Blocking is the honest answer.",[30,1074,1076],{"id":1075},"what-a-calculator-should-do-here","What a calculator should do here",[11,1078,1079],{},"Refuse.",[11,1081,1082],{},"That is not evasion, it is the only defensible behaviour. There are three ways software can respond\nto a missing benchmark:",[189,1084,1085,1091,1097],{},[192,1086,1087,1090],{},[15,1088,1089],{},"Pick a route."," Silently selects a different free allocation — for 7225 19 90 the published\nvalues range from 0.138 to 1.488, a factor of eleven. A wrong pick understates the obligation by\nan order of magnitude, and Article 26 penalises under-surrender at three to five times the\ncertificate price.",[192,1092,1093,1096],{},[15,1094,1095],{},"Treat the missing benchmark as zero."," Maximises the obligation instead. Wrong in the safe\ndirection, but still wrong, and it will not survive a verifier's question.",[192,1098,1099],{},[15,1100,1101],{},"Return no number, and say which code and which marker.",[11,1103,1104,1105,1108],{},"We do the third. Our calculation returns a typed ",[83,1106,1107],{},"blocked"," result carrying the reason, and writes no\nfigures at all — because a missing input coerced to zero is a silent under-report, and a guessed\nroute is a silent misstatement. The customer sees the CN code, the marker, and the sentence that this\nneeds an answer from the Commission or from counsel.",[11,1110,1111,1112,1115],{},"What we deliberately do ",[15,1113,1114],{},"not"," do is quietly resolve to the lowest published benchmark, even though\nthat would be the conservative direction. It would turn fifteen open legal questions into fifteen\ninvented answers, and nobody looking at the output would know which was which.",[30,1117,1119],{"id":1118},"the-one-thing-you-can-do-now","The one thing you can do now",[11,1121,1122,1123,1126],{},"If your goods fall under any of the fifteen codes, ask your supplier for the ",[15,1124,1125],{},"mill certificate"," —\nspecifically the alloying-element content. That is what decides carbon versus low-alloy, and it is\nthe fact neither the CN code nor the customs declaration carries. With verified actual emissions the\nroute question changes shape entirely, because you are no longer relying on the default table to tell\nyou which furnace to assume.",[11,1128,1129],{},"It does not dissolve the contradiction. But it moves you from \"the acts disagree about my goods\" to\n\"I can document what my goods actually are\" — which is the position you want to be in when somebody\nasks.",[217,1131],{},[11,1133,1134],{},[83,1135,1136],{},"This article explains the rules as we read them; it is not legal advice. The route markers and\ndefault values are set out in Implementing Regulation (EU) 2025\u002F2621 and its Annex I legend, the\nfree-allocation benchmarks and the grade definition in Implementing Regulation (EU) 2025\u002F2620\n(pt 5.2.3), and the penalty regime in Regulation (EU) 2023\u002F956 as amended. The counts above are from\nour own reference-data census for import year 2026 and are pinned in our test suite; verify your own\nposition with your customs agent or the competent authority in your member state — in Germany, the\nDEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":1138},[1139,1140,1141,1142,1143,1144],{"id":686,"depth":225,"text":687},{"id":780,"depth":225,"text":781},{"id":861,"depth":225,"text":862},{"id":991,"depth":225,"text":992},{"id":1075,"depth":225,"text":1076},{"id":1118,"depth":225,"text":1119},"2026-09-07","One implementing act assigns your steel a production route. The other publishes free-allocation benchmarks for a different set of routes. For 15 CN codes we cannot get the two to meet — so our calculation returns nothing rather than pick a route. Here are the codes, our derivation, and what would change our reading.","CBAM route marker, CBAM benchmark, IR 2025\u002F2620, IR 2025\u002F2621, CBAM free allocation steel, CN 7225 19 90, CBAM Annex I legend, CBAM default values steel grade, CBAM low-alloy steel",{},"\u002Fblog\u002Fcbam-two-acts-that-contradict-each-other",7,{"title":672,"description":1146},"blog\u002Fcbam-two-acts-that-contradict-each-other",[245,246],"luIDwCri1jbojbVDL95pbf9elBOs4Jyr1C5egwGVa80",{"id":1156,"title":1157,"body":1158,"date":1419,"description":1420,"extension":235,"hero":236,"heroAlt":236,"keywords":1421,"meta":1422,"navigation":239,"path":1423,"readingMinutes":241,"seo":1424,"stem":1425,"tags":1426,"__hash__":1428},"blog\u002Fblog\u002Fcbam-certificate-price-quarterly-2026.md","The CBAM price for this quarter doesn't exist yet",{"type":8,"value":1159,"toc":1410},[1160,1163,1166,1170,1177,1180,1214,1217,1223,1227,1230,1237,1240,1272,1275,1279,1282,1288,1291,1298,1302,1305,1326,1329,1340,1343,1347,1354,1361,1364,1368,1378,1384,1390,1396,1400,1403,1405],[11,1161,1162],{},"Today is the fifth of September. If you imported CBAM goods in July, you still cannot say what those\nimports cost you.",[11,1164,1165],{},"Not because your data is incomplete. Because the number does not exist yet.",[30,1167,1169],{"id":1168},"how-the-price-is-set-in-2026","How the price is set in 2026",[11,1171,1172,1173,1176],{},"A CBAM certificate is priced off the EU Emissions Trading System, but not off the live market. In\n2026 the price is the ",[15,1174,1175],{},"quarterly average of EU-ETS auction prices",", published by the Commission\n(Art. 21(1a) of Regulation (EU) 2023\u002F956 as amended by Regulation (EU) 2025\u002F2083; the cadence is set\nout in Implementing Regulation (EU) 2025\u002F2548, Art. 1(6)).",[11,1178,1179],{},"Two published figures exist so far:",[278,1181,1182,1192],{},[281,1183,1184],{},[284,1185,1186,1189],{},[287,1187,1188],{},"Period",[287,1190,1191],{},"Price per tonne CO₂",[300,1193,1194,1204],{},[284,1195,1196,1199],{},[305,1197,1198],{},"Q1 2026",[305,1200,1201],{},[15,1202,1203],{},"€75.36",[284,1205,1206,1209],{},[305,1207,1208],{},"Q2 2026",[305,1210,1211],{},[15,1212,1213],{},"€75.28",[11,1215,1216],{},"Q3 is not among them. An average of a quarter can only be computed once the quarter is over, so the\nQ3 figure is expected in early October — after every Q3 import has already cleared customs.",[11,1218,1219,1220],{},"That is not a gap in the rules. It is what \"quarterly average\" means. But it has a consequence people\nrarely plan for: ",[15,1221,1222],{},"for roughly three months of every quarter, the price attached to your imports is\nunknowable.",[30,1224,1226],{"id":1225},"the-number-attaches-to-the-import-not-to-the-purchase","The number attaches to the import, not to the purchase",[11,1228,1229],{},"This is the part that gets misfiled.",[11,1231,1232,1233,1236],{},"The price is resolved by the ",[15,1234,1235],{},"period of importation"," — not by the date you buy the certificate, not\nby the date you file. An import in July is valued at the Q3 price whether you compute it in July, in\nOctober, or in September 2027 when the annual declaration is due.",[11,1238,1239],{},"So the sequence for a July import is:",[189,1241,1242,1248,1254,1260,1266],{},[192,1243,1244,1247],{},[15,1245,1246],{},"July:"," the goods arrive. The obligation is fixed in tonnes of CO₂.",[192,1249,1250,1253],{},[15,1251,1252],{},"July–September:"," the price for that obligation does not exist.",[192,1255,1256,1259],{},[15,1257,1258],{},"Early October:"," the Commission publishes the Q3 average. Only now is the euro figure knowable.",[192,1261,1262,1265],{},[15,1263,1264],{},"From 1 February 2027:"," certificates can actually be bought.",[192,1267,1268,1271],{},[15,1269,1270],{},"30 September 2027:"," the annual declaration is due.",[11,1273,1274],{},"Between steps 1 and 3 you have a liability with a known quantity and an unknown price. That is a\nperfectly ordinary accounting situation — but only if you treat it as one.",[30,1276,1278],{"id":1277},"the-eight-cents-that-change-the-argument","The eight cents that change the argument",[11,1280,1281],{},"Here is where the intuition usually goes wrong. \"Quarterly price\" sounds like exposure to swings, so\nthe instinct is to worry about how far the number can move between quarters.",[11,1283,1284,1285],{},"Look at what actually happened. ",[15,1286,1287],{},"€75.36 to €75.28 — a difference of eight cents, about 0.1 %.",[11,1289,1290],{},"On 500 tonnes of CO₂, the two published quarters differ by forty euros. Whatever the risk in this\nmechanism is, it is not that the quarterly figure lurches.",[11,1292,1293,1294,1297],{},"Two caveats before anyone plans around that. Two quarters is not a trend, and the ETS itself is\nperfectly capable of moving; the quarterly average smooths daily movement, it does not remove it.\nWhat the smoothing does mean is that a quarterly average is a ",[83,1295,1296],{},"slow"," number by construction. The risk\nin a slow number is not that it jumps. It is that you book something else in its place and forget.",[30,1299,1301],{"id":1300},"what-people-book-instead","What people book instead",[11,1303,1304],{},"When the real figure is missing, something has to go in the cell. In practice it is one of three\nthings:",[1306,1307,1308,1314,1320],"ul",{},[192,1309,1310,1313],{},[15,1311,1312],{},"The live ETS price",", taken from a market feed on the day of the calculation.",[192,1315,1316,1319],{},[15,1317,1318],{},"The last published quarter",", carried forward.",[192,1321,1322,1325],{},[15,1323,1324],{},"A round number",", agreed once and never revisited.",[11,1327,1328],{},"All three are defensible as an accrual. None of them is the CBAM price, and that distinction survives\ninto the audit.",[11,1330,1331,1332,1335,1336,1339],{},"The failure is not choosing a proxy — you have to. The failure is a figure that no longer remembers\nit ",[83,1333,1334],{},"was"," a proxy. Six months later the cell says ",[45,1337,1338],{},"75.28"," and nobody can tell whether that is the\npublished Q2 average, a carried-forward guess, or a market quote from a Tuesday.",[11,1341,1342],{},"Any system that values CBAM obligations should carry the provenance next to the number: which period,\nwhich source, published or estimated. Ours refuses to substitute silently — when the quarterly figure\nis missing it falls back, but the result says so, and a figure marked as an estimate can never be\nmistaken for a published one. That is not a clever feature. It is the minimum for a number that will\nbe re-stated later.",[30,1344,1346],{"id":1345},"_2027-changes-the-shape-of-this-problem","2027 changes the shape of this problem",[11,1348,1349,1350,1353],{},"From 2027 the cadence moves from quarterly to ",[15,1351,1352],{},"weekly"," (same provisions). That mostly solves the\nwaiting: a week's average is available days after the week ends, not months.",[11,1355,1356,1357,1360],{},"It replaces it with a bookkeeping problem. Fifty-two prices a year instead of four means the ",[15,1358,1359],{},"date\nof each import"," stops being a detail and becomes the key that selects the price. If your import\nrecords are precise to the month, they are precise enough for 2026 and not for 2027.",[11,1362,1363],{},"That is worth checking now, while the consequence of getting it wrong is still small. Being in the\nwrong quarter is a rounding error today. Being in the wrong week, once the price moves weekly, is a\nnumber you cannot reconstruct without going back to the customs data.",[30,1365,1367],{"id":1366},"what-to-do-this-week","What to do this week",[11,1369,1370,1373,1374,1377],{},[15,1371,1372],{},"1. Find out what price your current figures are using."," Not the value — the ",[83,1375,1376],{},"source",". If the\nanswer is \"the ETS price\" or \"whatever was in the sheet\", that is fine as an accrual and a problem as\na record. Write down which it is, next to the number.",[11,1379,1380,1383],{},[15,1381,1382],{},"2. Check that every import carries its own import date."," Not the invoice date, not the month.\nThe import date is what selects the price, and from 2027 it selects it to the week.",[11,1385,1386,1389],{},[15,1387,1388],{},"3. Put a note in the calendar for early October."," When the Q3 figure publishes, your Q3 accruals\nbecome re-statable. If nobody owns that step, the proxy quietly becomes the final number.",[11,1391,1392,1395],{},[15,1393,1394],{},"4. Do not price certificates you cannot yet buy."," Trading opens on 1 February 2027. Anything\nbefore that is provisioning, not purchasing — and provisioning against a price that has not been\npublished is provisioning against an estimate, however precise the spreadsheet looks.",[30,1397,1399],{"id":1398},"the-part-that-is-genuinely-unresolved","The part that is genuinely unresolved",[11,1401,1402],{},"The Commission publishes the quarterly figure; it does not publish it on a statutory date that we\nhave been able to point to. \"Early October\" is an expectation drawn from the mechanics of a quarterly\naverage, not a deadline we can cite. If your process depends on the figure landing by a particular\nday, that dependency is on an assumption — plan for it to be late rather than discover that it is.",[217,1404],{},[11,1406,1407],{},[83,1408,1409],{},"This article explains the rules as we read them; it is not legal advice. The pricing mechanism is\nset out in Regulation (EU) 2023\u002F956 as amended by Regulation (EU) 2025\u002F2083, and in Implementing\nRegulation (EU) 2025\u002F2548. Published quarterly figures come from the Commission. Check your own\nposition with your customs agent or the competent authority in your member state — in Germany, the\nDEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":1411},[1412,1413,1414,1415,1416,1417,1418],{"id":1168,"depth":225,"text":1169},{"id":1225,"depth":225,"text":1226},{"id":1277,"depth":225,"text":1278},{"id":1300,"depth":225,"text":1301},{"id":1345,"depth":225,"text":1346},{"id":1366,"depth":225,"text":1367},{"id":1398,"depth":225,"text":1399},"2026-09-05","In 2026 the certificate price is a quarterly average the Commission publishes after the quarter has ended. So for three months you are importing against a number nobody can look up — and the two published quarters differ by eight cents, which tells you the real risk is timing, not volatility.","CBAM certificate price, CBAM Zertifikatspreis, CBAM quarterly average, CBAM weekly price 2027, Art 21(1a) CBAM, Regulation 2025\u002F2083, CBAM accrual, CBAM certificate price Q3 2026",{},"\u002Fblog\u002Fcbam-certificate-price-quarterly-2026",{"title":1157,"description":1420},"blog\u002Fcbam-certificate-price-quarterly-2026",[246,1427],"pricing","i9EJE9Gm9a-tILwELUAuw5fY4btJ2UuhkSa_JRrmprc",{"id":1430,"title":1431,"body":1432,"date":1692,"description":1693,"extension":235,"hero":236,"heroAlt":236,"keywords":1694,"meta":1695,"navigation":239,"path":1696,"readingMinutes":1150,"seo":1697,"stem":1698,"tags":1699,"__hash__":1701},"blog\u002Fblog\u002Fcbam-downstream-2028-deadline-2027.md","CBAM's new product list isn't settled. Your deadline already is.",{"type":8,"value":1433,"toc":1683},[1434,1441,1448,1452,1463,1474,1485,1488,1502,1506,1517,1520,1527,1531,1541,1544,1566,1571,1578,1582,1589,1595,1606,1609,1616,1620,1627,1630,1633,1637,1669,1673,1676,1678],[11,1435,1436,1437,1440],{},"If you import gearboxes, fasteners, radiators or washing machines, there is a good chance CBAM\nwill apply to you from ",[15,1438,1439],{},"1 January 2028",". There is also a good chance nobody has told you,\nbecause the file is still moving and the trade press has been covering the politics rather than\nthe dates.",[11,1442,1443,1444,1447],{},"Here is the part that gets lost: ",[15,1445,1446],{},"the year that decides your position is 2027, not 2028."," That\nis true whatever the final product list looks like, and it is true even though the law has not\nbeen adopted yet.",[30,1449,1451],{"id":1450},"where-the-file-actually-stands","Where the file actually stands",[11,1453,1454,1455,1458,1459,1462],{},"The Commission proposed the extension on ",[15,1456,1457],{},"17 December 2025"," (COM(2025) 989), covering ",[15,1460,1461],{},"180\ndownstream CN codes"," alongside a set of anti-circumvention measures.",[11,1464,1465,1466,1469,1470,1473],{},"The Council agreed its general approach on ",[15,1467,1468],{},"12 June 2026",". It refined the product list and — the\npart with the longest tail — instructed the Commission to ",[15,1471,1472],{},"review annually"," which further\ndownstream goods should be added.",[11,1475,1476,1477,1480,1481,1484],{},"Parliament's environment committee held an indicative vote on its position on ",[15,1478,1479],{},"6 July 2026",",\nwith adoption in plenary expected ",[15,1482,1483],{},"this month",". Reporting suggests Parliament wants to go\nfurther than the Council on scope. After that comes trilogue, with a final text expected late 2026\nor early 2027.",[11,1486,1487],{},"So there are three lists on the table and they do not match. We are not going to quote you a final\nnumber of product codes, because there isn't one yet, and every figure circulating today belongs\nto one institution's draft rather than to the law. Some of the counts being repeated are\nthemselves second-hand: the Council press release and several law-firm summaries are behind\naccess restrictions we could not read directly.",[11,1489,1490,1493,1494,1497,1498,1501],{},[15,1491,1492],{},"What is not in dispute is the date."," All three positions apply the extension from ",[15,1495,1496],{},"1 January\n2028",", with the first declaration due ",[15,1499,1500],{},"30 September 2029",".",[30,1503,1505],{"id":1504},"what-kind-of-goods-these-are","What kind of goods these are",[11,1507,1508,1509,1512,1513,1516],{},"According to the Commission's impact assessment, about ",[15,1510,1511],{},"94%"," of the affected downstream products\nare industrial supply-chain goods — inputs and components, not things on a shelf. Consumer\nhousehold products are roughly ",[15,1514,1515],{},"6%"," of the affected import volume.",[11,1518,1519],{},"The categories being discussed across the three positions are consistent even where the counts are\nnot: fabricated metal products, machinery and industrial equipment, vehicle components such as\ngearboxes and engines, domestic appliances such as washing machines and refrigerators, and metal\nconstruction equipment. Passenger cars themselves have been kept out.",[11,1521,1522,1523,1526],{},"The common thread is that these are ",[15,1524,1525],{},"steel- and aluminium-intensive manufactured goods",". This is\nnot CBAM branching into new materials. It is the same two metals, one processing step further\nalong, which is precisely the gap the anti-circumvention part of the proposal is meant to close:\ntoday you can import a finished component free of CBAM while the raw metal that went into it would\nhave been in scope.",[30,1528,1530],{"id":1529},"why-the-deadline-lands-a-year-early","Why the deadline lands a year early",[11,1532,1533,1534,1537,1538,1501],{},"CBAM obligations do not begin when you file. They begin when you ",[15,1535,1536],{},"import",", and to import in\nscope you must already be an ",[15,1539,1540],{},"authorised CBAM declarant",[11,1542,1543],{},"Two provisions do the work here, and together they move the real deadline forward by a year:",[1306,1545,1546,1556],{},[192,1547,1548,1551,1552,1555],{},[15,1549,1550],{},"Article 5(1b)"," attaches the duty to apply to the ",[83,1553,1554],{},"expectation"," of exceeding the threshold, not\nto the outcome. You are not permitted to wait, cross 50 tonnes, and then apply.",[192,1557,1558,1561,1562,1565],{},[15,1559,1560],{},"Implementing Regulation (EU) 2025\u002F486, Article 4(1)"," gives the competent authority up to\n",[15,1563,1564],{},"120 days"," to decide on an application.",[11,1567,1568,1569,1501],{},"Put those together. If you expect to import more than 50 tonnes of newly-covered goods during\n2028, your authorisation has to be in hand before your first shipment of that year. Four months of\nstatutory processing time, plus the time it takes you to assemble the application, means the work\nbelongs in ",[15,1570,347],{},[11,1572,1573,1574,1577],{},"That is why the unsettled product list matters less than it looks. If your goods are anywhere near\nthe categories above, the planning question — ",[83,1575,1576],{},"do we expect to cross 50 tonnes?"," — has to be\nanswered before the list is final, because the clock is longer than the remaining legislative\nprocess.",[30,1579,1581],{"id":1580},"the-threshold-arithmetic-and-one-honest-gap","The threshold arithmetic, and one honest gap",[11,1583,1584,1585,1588],{},"The 50-tonne de-minimis is defined in Regulation (EU) 2025\u002F2083, recital 3, as a threshold based\non the ",[15,1586,1587],{},"cumulative net mass of the imported goods"," in a calendar year per importer, applied\nacross all covered sectors together — not per shipment, not per product type.",[11,1590,1591,1592,1594],{},"For downstream goods there is a question we have ",[15,1593,1114],{}," been able to settle at primary text:\nwhether that same net-mass basis carries over, or whether the relevant mass is only the metal\ncontent of the finished article. Secondary commentary suggests emissions would be attributed only\nto the precursor metal, which is a different question from how the threshold is measured, and the\ntwo get conflated easily.",[11,1596,1597,1598,1601,1602,1605],{},"The difference is not academic. At an average metal content around 79%, the two readings are about\n27% apart in units. For a 70 kg washing machine that is roughly ",[15,1599,1600],{},"714 units"," versus ",[15,1603,1604],{},"1,190"," to\nreach the same threshold. If you are near the line, that gap decides whether you are in scope.",[11,1607,1608],{},"We would rather tell you this is open than guess it. When the final text lands, it is one of the\nfirst things worth reading properly.",[11,1610,1611,1612,1615],{},"What is already clear is that ",[15,1613,1614],{},"50 tonnes is a low bar for this class of goods",". Downstream\nproducts are light and expensive per tonne compared with the coils and billets CBAM has covered so\nfar — a steel coil alone weighs 25 to 30 tonnes, so two of them clear the threshold. Reaching 50\ntonnes in fasteners, motors or appliances takes a lot more units, but it is an ordinary annual\nvolume for a mid-sized manufacturer or distributor. Whoever crosses this line will tend to cross\nit narrowly, which is exactly the position where the answer is least obvious.",[30,1617,1619],{"id":1618},"the-quieter-problem-nobody-has-done-this-before","The quieter problem: nobody has done this before",[11,1621,1622,1623,1626],{},"Around ",[15,1624,1625],{},"18,000 importers"," are in scope today (Commission staff working document SWD(2025) 58,\nTable 1). Most of them have been filing quarterly reports since 2023 and have somebody who knows\nwhat a CN code is.",[11,1628,1629],{},"The importers arriving in 2028 are a different population. A machinery builder importing motors has\nnever filed a CBAM report, has no customs department, and in many cases has no idea the file\nexists. The extension does not make CBAM harder for people who already do it — it hands it to\npeople who have never done it, with a first deadline that arrives before their first declaration.",[11,1631,1632],{},"If you are in that group, the advantage of finding out now is simply time. Nothing about this is\ntechnically difficult. It is administratively unforgiving.",[30,1634,1636],{"id":1635},"what-to-do-this-year","What to do this year",[189,1638,1639,1645,1651,1657,1663],{},[192,1640,1641,1644],{},[15,1642,1643],{},"Check your CN codes against the three draft lists, not just one."," If your goods appear in any\nof them, plan as if you are in. Trilogue narrows and widens lists; it rarely removes an entire\ncategory that all three institutions put in.",[192,1646,1647,1650],{},[15,1648,1649],{},"Estimate your 2028 volume in net mass now",", cumulatively across all CBAM goods you import —\nincluding anything already in scope today. The threshold is one number for everything, not one\nper product group.",[192,1652,1653,1656],{},[15,1654,1655],{},"If the answer is anywhere near 50 tonnes, start the authorisation in 2027."," Not after the\nfirst shipment. The 120 days is a ceiling on the authority's side; your own preparation comes on\ntop.",[192,1658,1659,1662],{},[15,1660,1661],{},"Ask your suppliers what emissions data they can produce"," — and by when. This is the item with\nthe longest lead time and the one most likely to be outside your control.",[192,1664,1665,1668],{},[15,1666,1667],{},"Watch the Parliament vote this month."," It sets the outer edge of the scope going into\ntrilogue, and it is the last public signal before the text is negotiated behind closed doors.",[30,1670,1672],{"id":1671},"what-we-would-not-do","What we would not do",[11,1674,1675],{},"We would not wait for the final text before estimating volumes. The estimate does not depend on the\nlist being final — it depends on your own purchasing, which you already know. And we would not\nassume that a product missing from the Commission's original 180 is safe: the Council's annual\nreview mandate means Annex I stops being a fixed list from 2028 onwards. Whatever is agreed is a\nstarting point, not a settlement.",[217,1677],{},[11,1679,1680],{},[83,1681,1682],{},"This article describes proposed legislation that has not been adopted. Product lists, thresholds\nand dates may change in trilogue. It is general information, not legal advice; for your own\nposition, check the final text and speak to a qualified adviser.",{"title":47,"searchDepth":225,"depth":225,"links":1684},[1685,1686,1687,1688,1689,1690,1691],{"id":1450,"depth":225,"text":1451},{"id":1504,"depth":225,"text":1505},{"id":1529,"depth":225,"text":1530},{"id":1580,"depth":225,"text":1581},{"id":1618,"depth":225,"text":1619},{"id":1635,"depth":225,"text":1636},{"id":1671,"depth":225,"text":1672},"2026-09-04","The extension to downstream goods applies on 1 January 2028, and three EU institutions still disagree on which products are in. None of that changes the year you have to act — because authorisation takes up to 120 days and has to exist before you cross the threshold.","CBAM downstream extension, COM(2025) 989, CBAM 2028, CBAM machinery parts, CBAM fasteners, CBAM authorised declarant 120 days, CBAM 50 tonnes threshold, CBAM trilogue, CBAM anti-circumvention",{},"\u002Fblog\u002Fcbam-downstream-2028-deadline-2027",{"title":1431,"description":1693},"blog\u002Fcbam-downstream-2028-deadline-2027",[246,1700],"deadlines","BJjeQPf_6vHBJ9_DmvS9ppTS5__S_F6VycGU3fKNe-I",{"id":1703,"title":1704,"body":1705,"date":1952,"description":1953,"extension":235,"hero":236,"heroAlt":236,"keywords":1954,"meta":1955,"navigation":239,"path":1956,"readingMinutes":241,"seo":1957,"stem":1958,"tags":1959,"__hash__":1961},"blog\u002Fblog\u002Fsteel-safeguard-2026-and-cbam.md","The EU just halved the steel quota. Your CBAM position moved with it.",{"type":8,"value":1706,"toc":1944},[1707,1714,1744,1759,1762,1765,1769,1776,1779,1782,1785,1789,1792,1799,1802,1805,1809,1820,1823,1833,1843,1856,1860,1863,1869,1876,1887,1889,1899,1905,1911,1917,1921,1924,1934,1937,1939],[11,1708,1709,1710,1713],{},"On ",[15,1711,1712],{},"1 July 2026"," the EU replaced its steel safeguard with a much tighter one\n(Regulation (EU) 2026\u002F1384). Three numbers from it have been widely reported:",[1306,1715,1716,1727,1733],{},[192,1717,1718,1719,1722,1723,1726],{},"the tariff-free quota fell ",[15,1720,1721],{},"47%",", to ",[15,1724,1725],{},"18,345,922 tonnes"," a year",[192,1728,1729,1730],{},"the duty on anything above the quota ",[15,1731,1732],{},"doubled, from 25% to 50%",[192,1734,1735,1736,1739,1740,1743],{},"the scope grew from ",[15,1737,1738],{},"28 to 30"," product categories, and a ",[15,1741,1742],{},"\"melt and pour\""," rule now ties\norigin to where the steel was actually made, not where it was last processed",[11,1745,1746,1747,1750,1751,1754,1755,1758],{},"What has been reported far less is how the Commission arrived at that quota. It took the import\nshare the EU had in ",[15,1748,1749],{},"2013 — about 13%"," — and applied it to 2024 consumption. That is the stated\ndestination. For comparison, extra-EU steel was ",[15,1752,1753],{},"27% of EU consumption in 2024"," and averaged\naround ",[15,1756,1757],{},"30% in 2025"," (EUROFER).",[11,1760,1761],{},"So the measure is not a nudge. It is an explicit plan to cut third-country steel roughly in half.",[11,1763,1764],{},"And that is where it stops being only a trade story.",[30,1766,1768],{"id":1767},"cbam-only-exists-at-the-border","CBAM only exists at the border",[11,1770,1771,1772,1775],{},"CBAM applies to goods ",[15,1773,1774],{},"imported"," into the EU. Steel from a mill inside the union is not in scope —\nnot a lower rate, not a simpler form: out of scope entirely, because its carbon is already priced\nby the EU ETS.",[11,1777,1778],{},"Which means the safeguard is, incidentally, a CBAM-reduction programme. Every tonne a buyer moves\nfrom a third country to an EU mill is a tonne that leaves the CBAM perimeter.",[11,1780,1781],{},"If your response to a 50% out-of-quota duty is to buy more inside the EU — and for many buyers it\nwill be — your CBAM exposure falls without you doing anything about CBAM.",[11,1783,1784],{},"That is the good news, and it is the last simple thing in this article.",[30,1786,1788],{"id":1787},"moving-between-third-countries-is-not-neutral","Moving between third countries is not neutral",[11,1790,1791],{},"The other obvious response is to keep buying outside the EU but switch to whoever still has quota.\nThat works for the duty. It does not leave your carbon bill where it was.",[11,1793,1794,1795,1798],{},"CBAM default values are published ",[15,1796,1797],{},"per country of origin, per CN code, per year"," (Annex I,\nImplementing Regulation (EU) 2025\u002F2621). They are not a global average. Two mills making the same\nproduct to the same standard carry different figures depending on which country they sit in — that\nis the whole design of the instrument.",[11,1800,1801],{},"So a sourcing decision taken purely on duty and lead time silently reprices the carbon side. It can\ngo either way, and the two effects have nothing to do with each other: the country with spare quota\nis not systematically the country with the lower default value.",[11,1803,1804],{},"If you switch origin this year, the honest position is that you do not know what happened to your\nCBAM bill until you look up the new figure.",[30,1806,1808],{"id":1807},"the-threshold-is-where-it-gets-sharp","The threshold is where it gets sharp",[11,1810,1811,1812,1815,1816,1819],{},"CBAM's entry point is a mass threshold: ",[15,1813,1814],{},"50 tonnes of net mass per importer per calendar year",",\ncumulative across ",[15,1817,1818],{},"all"," CBAM goods aggregated — iron and steel, aluminium, fertilisers and cement\ntogether (Art. 2a). Above it, everything applies. At or below it, you are exempt.",[11,1821,1822],{},"A buyer who cuts third-country steel hard enough can land under that line. Three things about that\nare worth knowing before anyone treats it as a plan.",[11,1824,1825,1828,1829,1832],{},[15,1826,1827],{},"First: the exemption is not passive."," Below the threshold you must ",[15,1830,1831],{},"declare the exemption in the\ncustoms declaration"," itself. It is a positive act on every consignment, not a silence.",[11,1834,1835,1838,1839,1842],{},[15,1836,1837],{},"Second: the year does not restart on 1 July."," The safeguard applied from the middle of the\ncalendar year. The CBAM threshold counts the ",[15,1840,1841],{},"whole"," year. Tonnes imported in the first half —\nunder the old, larger quota — still count. A buyer who stops entirely in July can still be over the\nline for 2026 on January-to-June volume alone.",[11,1844,1845,1851,1852,1855],{},[15,1846,1847,1848,1850],{},"Third: the duty to apply for authorisation hangs on ",[83,1849,1554],{},", not outcome."," Art. 5(1b)\nrequires the application from an importer who ",[15,1853,1854],{},"expects"," to exceed. If you expected to cross and\nthen, because of the safeguard, did not, you were still right to apply. And the reverse case is the\none that bites: an importer who honestly did not expect to exceed and then did has no Art. 5(1b)\nduty — and is penalised under Art. 26(2a) anyway.",[30,1857,1859],{"id":1858},"the-safety-valve-almost-nobody-mentions","The safety valve almost nobody mentions",[11,1861,1862],{},"Suppose you did expect to cross, applied, were authorised, and then bought so much less from outside\nthe EU that you finished the year below 50 tonnes. You are exempt. What about the certificates?",[11,1864,1865,1868],{},[15,1866,1867],{},"Art. 23(2): they are all repurchased on request."," Not a proportion, not subject to a cap —\nwhoever bought on the expectation of exceeding and then did not exceed gets the lot bought back.",[11,1870,1871,1872,1875],{},"This is worth writing down now because it becomes live next year: certificate sales do not start\nuntil ",[15,1873,1874],{},"1 February 2027"," (Art. 20(1)). Nobody holds a 2026 certificate today. But 2027 is exactly\nthe year in which buyers will be sizing purchases against a quota regime they have only half a\nyear's experience of — and the provision that protects an over-cautious buyer is one paragraph in a\nregulation most people have never opened.",[11,1877,1878,1879,1882,1883,1886],{},"Note the shape of the year, though: certificates for 2026 may only be repurchased ",[15,1880,1881],{},"in 2027","\n(Art. 23(2a)), and whatever is left of that vintage is ",[15,1884,1885],{},"cancelled without compensation on\n1 November 2027"," (Art. 24(2)). The window is real but it is not wide.",[30,1888,1367],{"id":1366},[11,1890,1891,1894,1895,1898],{},[15,1892,1893],{},"1. Pull your first-half tonnage."," Not the value, the ",[15,1896,1897],{},"net mass",", across every CBAM good, not\njust steel. That is the number the threshold is measured in, and it is already fixed for 2026 — no\nsourcing decision you take now can reduce it.",[11,1900,1901,1904],{},[15,1902,1903],{},"2. Project the second half under the new duty."," If your buyers are already shifting to EU mills,\nyour extra-EU mass may be flattening. Add the two halves. Are you over 50 tonnes for the year, or not?",[11,1906,1907,1910],{},[15,1908,1909],{},"3. If the answer changed, write down when it changed and why."," An importer whose expectation moved\nduring the year — in either direction — has a decision to document, not just a number to file. That\nis true whether the move takes you into scope or out of it.",[11,1912,1913,1916],{},[15,1914,1915],{},"4. If you switched origin, re-check the default value."," Same CN code, different country, different\nfigure. It takes a minute and it is the single most likely place for this year's carbon bill to have\nmoved without anyone noticing.",[30,1918,1920],{"id":1919},"two-regimes-one-shipment","Two regimes, one shipment",[11,1922,1923],{},"It is tempting to read the safeguard and CBAM as the same policy in two costumes — both make foreign\nsteel more expensive, both push toward European supply. They are not.",[11,1925,1926,1927,1930,1931,1933],{},"The safeguard is a ",[15,1928,1929],{},"quantity"," instrument: it cares how much comes in, and it stops caring once you\nare inside the quota. CBAM is a ",[15,1932,726],{}," instrument: it does not care how much you import, only\nwhat the production of it emitted, and it never stops applying above the threshold.",[11,1935,1936],{},"Optimise for one and you move inside the other. The buyers who come out of 2026 in good shape will\nbe the ones who noticed that the two questions have different answers — and asked both.",[217,1938],{},[11,1940,1941],{},[83,1942,1943],{},"This article explains the rules as we read them; it is not legal advice. The safeguard is\nRegulation (EU) 2026\u002F1384, applicable from 1 July 2026. The CBAM provisions cited are in Regulation\n(EU) 2023\u002F956 as amended by Regulation (EU) 2025\u002F2083, with default values in Implementing\nRegulation (EU) 2025\u002F2621. Quota volumes and duty rates change; check the current tariff-rate quota\nposition with your customs agent before acting on any of it.",{"title":47,"searchDepth":225,"depth":225,"links":1945},[1946,1947,1948,1949,1950,1951],{"id":1767,"depth":225,"text":1768},{"id":1787,"depth":225,"text":1788},{"id":1807,"depth":225,"text":1808},{"id":1858,"depth":225,"text":1859},{"id":1366,"depth":225,"text":1367},{"id":1919,"depth":225,"text":1920},"2026-09-03","Since 1 July 2026 the tariff-free steel quota is 47% smaller and the out-of-quota duty is 50%. Buying less from outside the EU lowers your carbon bill — and can quietly change whether CBAM applies to you at all.","EU steel safeguard 2026, Regulation 2026\u002F1384, steel tariff rate quota, 50 percent out of quota duty, melt and pour, CBAM 50 tonnes threshold, CBAM sourcing, CBAM default values origin",{},"\u002Fblog\u002Fsteel-safeguard-2026-and-cbam",{"title":1704,"description":1953},"blog\u002Fsteel-safeguard-2026-and-cbam",[246,1960],"am I affected","amlL0Xkww-U6gV2878OaxFj_G1fsLId8PDMJE_4fJAo",{"id":1963,"title":1964,"body":1965,"date":2199,"description":2200,"extension":235,"hero":2201,"heroAlt":2202,"keywords":2203,"meta":2204,"navigation":239,"path":2205,"readingMinutes":1150,"seo":2206,"stem":2207,"tags":2208,"__hash__":2209},"blog\u002Fblog\u002Fcbam-actual-vs-default-values.md","Actual values or default values — and what the choice really costs",{"type":8,"value":1966,"toc":2191},[1967,1978,1985,1989,1996,2007,2010,2028,2032,2035,2050,2075,2086,2092,2096,2099,2122,2125,2129,2136,2139,2141,2147,2153,2163,2169,2173,2184,2186],[11,1968,1969,1970,1973,1974,1977],{},"There are two ways to put an emissions number on an imported good. You can use the EU ",[15,1971,1972],{},"default value","\nfor that good and origin — a figure you look up in a table — or you can use your supplier's ",[15,1975,1976],{},"actual","\nmeasured emissions. Since the Omnibus amendment (Regulation (EU) 2025\u002F2083) the choice is genuinely\nfree: Art. 7(2) lets the declarant elect either, with no condition attached.",[11,1979,1980,1981,1984],{},"The instinct is that actual values are the better deal. They are more precise, and a clean supplier's\nreal emissions are usually ",[15,1982,1983],{},"below"," the conservative default — so the actual path looks like a lower\nbill. For most importers that instinct is wrong, and it is wrong before any emissions are compared,\nbecause of what the actual path drags in behind it.",[30,1986,1988],{"id":1987},"what-the-actual-path-actually-requires","What the actual path actually requires",[11,1990,1991,1992,1995],{},"Choosing actual values is not \"write a smaller number in the same box.\" Art. 7(2)(a) pulls Art. 8 in\nwith it, and Art. 8 requires the emissions to be ",[15,1993,1994],{},"verified by an accredited verifier."," A default\nvalue needs no verifier at all — that is the entire point of a default.",[11,1997,1998,1999,2002,2003,2006],{},"Accredited verification is not a form. It is an audited assessment of a ",[15,2000,2001],{},"production installation's","\nemissions, against the CBAM methodology, by a body accredited for it. Industry pricing for a single\ninstallation runs in the region of ",[15,2004,2005],{},"EUR 12,000 to 25,000",", and it recurs — a verification covers a\nperiod, not forever.",[11,2008,2009],{},"Two more things travel with the actual path, and both are load-bearing:",[1306,2011,2012,2018],{},[192,2013,2014,2017],{},[15,2015,2016],{},"The data has to exist and be shared with you."," You cannot verify your supplier's installation\nyourself; the operator has it verified, publishes it to the third-country installations register,\nand passes the figure to you in a CBAM communication. A supplier who has not done this cannot give\nyou an actual value, however clean their plant.",[192,2019,2020,2023,2024,2027],{},[15,2021,2022],{},"There is no accredited verifier to use yet."," The accreditation of CBAM verifiers does not open\nuntil around ",[15,2025,2026],{},"1 September 2026."," For imports before that, the actual path is not merely expensive —\nit is unavailable, and the default path is the only lawful basis.",[30,2029,2031],{"id":2030},"the-break-even-and-why-it-usually-isnt-close","The break-even, and why it usually isn't close",[11,2033,2034],{},"Here is the arithmetic that settles it for most importers, and it does not depend on knowing your\nsupplier's real number.",[11,2036,2037,2038,2041,2042,2045,2046,2049],{},"The ",[15,2039,2040],{},"most"," an actual value can ever save you is your ",[15,2043,2044],{},"entire default obligation."," The figure can\nonly go down, and the floor is zero certificates. So the verifier can only pay for itself when your\nannual default levy — on the goods from that one installation — is already larger than the verifier's\nfee. Below roughly ",[15,2047,2048],{},"EUR 12,000 of annual levy",", verification is a guaranteed loss, no matter how low\nthe real emissions turn out to be.",[11,2051,2052,2053,2058,2059,2062,2063,2066,2067,2070,2071,2074],{},"Put that against a concrete figure. In ",[2054,2055,2057],"a",{"href":2056},"\u002Fblog\u002Fcbam-two-numbers-most-calculations-get-wrong","an earlier worked example","\nthe default obligation on steel came to about ",[15,2060,2061],{},"EUR 114 per tonne of goods"," (CN 7208 51 20, origin\nArgentina, 2026). At that rate the break-even sits near ",[15,2064,2065],{},"105 tonnes a year, from a single\ninstallation"," — and that is the point at which the actual path ",[83,2068,2069],{},"could"," start to pay only if the real\nvalue were near zero. To save anything ",[15,2072,2073],{},"net",", you need materially more.",[11,2076,2077,2078,2081,2082,2085],{},"Now the small-importer case the threshold rules out entirely. Take ",[15,2079,2080],{},"60 tonnes of the same steel."," The\nwhole default obligation is around ",[15,2083,2084],{},"EUR 6,800."," Even if verification drove the number to zero — the\nbest case that can exist — the saving is EUR 6,800 against a verifier that starts at EUR 12,000. The\narithmetic forecloses it. A 60-tonne importer cannot save 12,000 euros out of an obligation of 6,800,\nand no amount of supplier cleanliness changes that.",[11,2087,2088,2089],{},"This is the uncomfortable part for anyone selling \"we'll get you your accurate, lower number\": for a\nlarge share of importers the accurate number is real, lower, and ",[15,2090,2091],{},"not worth having.",[30,2093,2095],{"id":2094},"when-actual-values-do-pay","When actual values do pay",[11,2097,2098],{},"They are not a trap — they are a volume play. The actual path earns its verifier fee when:",[1306,2100,2101,2108,2115],{},[192,2102,2103,2104,2107],{},"your annual tonnage from ",[15,2105,2106],{},"one"," installation is high enough that the default levy comfortably clears\nthe fee (steel in the hundreds of tonnes, more for lower-value goods);",[192,2109,2110,2111,2114],{},"the supplier's verified emissions are ",[15,2112,2113],{},"materially"," below the default, not marginally;",[192,2116,2117,2118,2121],{},"and the verification cost is ",[15,2119,2120],{},"shared"," across every shipment from that installation for the period —\nwhich is why it favours importers with a stable, concentrated supply chain over ones who buy a\ncontainer here and there from whoever is cheapest.",[11,2123,2124],{},"If you import a lot, from few installations, from producers who have already verified for the EU market,\nactual values can be the right call. That is a specific shape of importer, and it is worth knowing\nwhether you are one before you pay for verification.",[30,2126,2128],{"id":2127},"the-part-you-cannot-do-halfway","The part you cannot do halfway",[11,2130,2131,2132,2135],{},"One more reason the choice is bigger than a single field: ",[15,2133,2134],{},"you cannot keep the default's free\nallocation while swapping in an actual emissions number."," The free-allocation basis follows the\nemissions basis. On the default path you deduct a Column B (cradle-to-good) benchmark; the actual path\nis calculated on a different footing (Implementing Regulation (EU) 2025\u002F2620, Art. 2 and 3). Taking a\nlow actual value and still subtracting the default-path benchmark mixes two yardsticks in one\nsubtraction and produces a figure with no legal basis — and it is the kind of figure that looks fine\nuntil someone reconciles it.",[11,2137,2138],{},"So \"actual values\" is not a discount you toggle on. It is a different calculation, a different evidence\nrequirement, and a recurring cost — chosen as a whole or not at all.",[30,2140,187],{"id":186},[11,2142,2143,2146],{},[15,2144,2145],{},"1. Total your annual tonnage per installation, not per shipment."," The break-even lives at the\ninstallation level. Fragmented buying from many small suppliers almost never reaches it.",[11,2148,2149,2152],{},[15,2150,2151],{},"2. Ask whether your supplier already has verified emissions for the EU."," If they do, and you buy in\nvolume, the actual path may pay — get the CBAM communication and the verifier's report. If they don't,\nyour only near-term basis is the default value, and that is fine.",[11,2154,2155,2162],{},[15,2156,2157,2158,2161],{},"3. Compare the ",[83,2159,2160],{},"whole default levy"," to the verifier fee before anything else."," If the entire\nobligation from that installation is smaller than about EUR 12,000, stop — the actual path cannot win,\nand the time is better spent making the default calculation correct.",[11,2164,2165,2168],{},[15,2166,2167],{},"4. Remember the timing."," For imports before verifier accreditation opens (~September 2026), default\nvalues are not a fallback — they are the only lawful basis.",[30,2170,2172],{"id":2171},"the-short-version","The short version",[11,2174,2175,2176,2179,2180,2183],{},"Actual values are more accurate, often lower, and for a large share of importers ",[15,2177,2178],{},"not worth the\nverifier they require."," The decision is not \"which number is smaller\" — it is \"does the smaller number\nsave more than EUR 12,000-plus a year, from this installation, net.\" For anyone importing modest\nvolumes, the default value is not a compromise. It is the correct and cheaper answer, and the effort\nbelongs in getting ",[83,2181,2182],{},"that"," calculation right.",[217,2185],{},[11,2187,2188],{},[83,2189,2190],{},"This article explains the rules as we read them; it is not legal advice. The free choice of basis is\nin Regulation (EU) 2023\u002F956 Art. 7(2) as amended by Regulation (EU) 2025\u002F2083; the verification\nrequirement in Art. 8; the free-allocation basis in Implementing Regulation (EU) 2025\u002F2620. Verifier\npricing is indicative market research, not a quote. Verify your own position with your customs agent or\nthe competent authority in your member state — in Germany, the DEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":2192},[2193,2194,2195,2196,2197,2198],{"id":1987,"depth":225,"text":1988},{"id":2030,"depth":225,"text":2031},{"id":2094,"depth":225,"text":2095},{"id":2127,"depth":225,"text":2128},{"id":186,"depth":225,"text":187},{"id":2171,"depth":225,"text":2172},"2026-08-27","Since the Omnibus you may declare your supplier's actual emissions instead of the EU defaults. It sounds like the cheaper, more accurate path. For most importers the arithmetic forecloses it before it begins — the verifier costs more than the whole obligation could ever save.","https:\u002F\u002Fy7cuzzvjaoml1mzf.public.blob.vercel-storage.com\u002Fblog-5.webp","An old brass balance scale on a dark steel workbench: one pan holds a thick wax-sealed verification report, the other a single thin printed table card, the sealed report weighing the heavier","CBAM actual values, CBAM default values, CBAM Art 7(2), CBAM accredited verifier, CBAM Art 8, CBAM verification cost, CBAM Ist-Werte Standardwerte, CBAM Prüfer, embedded emissions verification",{},"\u002Fblog\u002Fcbam-actual-vs-default-values",{"title":1964,"description":2200},"blog\u002Fcbam-actual-vs-default-values",[245,246],"CM-nZY6Qce1tMVd1UnebaOw1PMhYkT4ZPVeotYhuElo",{"id":2211,"title":2212,"body":2213,"date":2506,"description":2507,"extension":235,"hero":2508,"heroAlt":2509,"keywords":2510,"meta":2511,"navigation":239,"path":2056,"readingMinutes":1150,"seo":2512,"stem":2513,"tags":2514,"__hash__":2515},"blog\u002Fblog\u002Fcbam-two-numbers-most-calculations-get-wrong.md","The two numbers most CBAM calculations get wrong",{"type":8,"value":2214,"toc":2494},[2215,2218,2225,2228,2232,2238,2244,2280,2283,2290,2295,2298,2304,2307,2314,2318,2321,2328,2334,2345,2375,2381,2385,2388,2402,2409,2415,2422,2429,2434,2438,2441,2448,2451,2453,2456,2462,2468,2474,2477,2481,2484,2487,2489],[11,2216,2217],{},"CBAM arithmetic looks simple enough to do in a spreadsheet. Mass, an emissions figure, a price, a\ncouple of factors. Most people who try it get an answer, and the answer looks plausible.",[11,2219,2220,2221,2224],{},"Two of those factors are routinely applied to the wrong thing. Not miscalculated — ",[15,2222,2223],{},"misplaced."," The\nnumbers are right; they are multiplied against the wrong quantity. One of the two inflates the result\nby roughly twenty times. The other understates it, which is the more dangerous direction.",[11,2226,2227],{},"We know the second one intimately, because it was in our own shipped code before we caught it.",[30,2229,2231],{"id":2230},"mistake-one-the-mark-up-rises-with-the-calendar-not-with-the-material","Mistake one: the mark-up rises with the calendar, not with the material",[11,2233,2234,2235,1501],{},"The EU default values in Implementing Regulation (EU) 2025\u002F2621 carry a statutory mark-up. Ask around\nand you will hear it described as a property of the goods — ",[83,2236,2237],{},"steel is twenty percent, cement is ten",[11,2239,2240,2241],{},"It isn't. ",[15,2242,2243],{},"The mark-up is a property of the reporting year.",[278,2245,2246,2256],{},[281,2247,2248],{},[284,2249,2250,2253],{},[287,2251,2252],{},"Reporting year",[287,2254,2255],{},"Mark-up on the default value",[300,2257,2258,2265,2272],{},[284,2259,2260,2262],{},[305,2261,307],{},[305,2263,2264],{},"+10 %",[284,2266,2267,2269],{},[305,2268,347],{},[305,2270,2271],{},"+20 %",[284,2273,2274,2277],{},[305,2275,2276],{},"2028 and later",[305,2278,2279],{},"+30 %",[11,2281,2282],{},"Same goods, same origin, same production route — the figure rises purely because the calendar moved.\nThe annex publishes three year columns for every row, and they differ only by that factor.",[11,2284,2285,2286,2289],{},"There is exactly one exception, and it is a large one: ",[15,2287,2288],{},"fertilisers carry a flat 1 %, in every year.","\nNot 10, not 20, not 30. Across the published table that exception covers a few thousand rows, so if\nyou import fertiliser and someone has applied the steel logic to it, your number is out by about a\nquarter.",[2291,2292,2294],"h3",{"id":2293},"the-rows-where-multiply-by-12-fails","The rows where \"multiply by 1.2\" fails",[11,2296,2297],{},"Here is the detail that makes the shortcut dangerous rather than merely imprecise.",[11,2299,2300,2301],{},"The act does not publish a raw value and leave you to apply the mark-up. It publishes the marked-up\nfigure for each year, and on ",[15,2302,2303],{},"five rows it compounds the mark-up instead of stepping it.",[11,2305,2306],{},"Those five rows are cement from Angola and Argentina. Where every other row goes ×1.10, ×1.20, ×1.30,\nthese go ×1.10, ×1.21, ×1.331. On a 2028 figure that is a 2.4 % difference — small, and precisely the\nkind of small that survives review and shows up years later in a correction.",[11,2308,2309,2310,2313],{},"The lesson generalises: ",[15,2311,2312],{},"read the year's value out of the annex; never derive it."," Any process that\nstores one number and computes the others will be wrong on those rows, and will look right everywhere\nelse.",[30,2315,2317],{"id":2316},"mistake-two-free-allocation-reduces-the-deduction-not-your-emissions","Mistake two: free allocation reduces the deduction, not your emissions",[11,2319,2320],{},"This is the expensive one, and it is easy to see why people get it wrong.",[11,2322,2323,2324,2327],{},"The phase-out schedule is usually described as ",[83,2325,2326],{},"\"free allocation falls away: 2.5 % is withdrawn in\n2026, 5 % in 2027, 10 % in 2028.\""," Those percentages are correct. The natural next step is to\nmultiply your embedded emissions by them — 2.5 % of your carbon is what you pay for in 2026.",[11,2329,2330,2331,694],{},"That reading is wrong, and it is wrong by a lot. The regulation does not scale your emissions. It\nscales ",[15,2332,2333],{},"the benchmark you are allowed to deduct",[78,2335,2336],{},[11,2337,2338,2341,2342],{},[15,2339,2340],{},"Certificates = max(0, M × (SEE − SEFA))",", where ",[15,2343,2344],{},"SEFA = CBAM_y × CSCF_y × BM",[1306,2346,2347,2353,2359,2369],{},[192,2348,2349,2352],{},[15,2350,2351],{},"SEE"," — the specific embedded emissions of your goods (the marked-up default value, on the\ndefault path)",[192,2354,2355,2358],{},[15,2356,2357],{},"BM"," — the EU benchmark for that good",[192,2360,2361,2364,2365,2368],{},[15,2362,2363],{},"CBAM_y"," — the ",[83,2366,2367],{},"remaining"," free allocation: 0.975 in 2026, 0.95 in 2027, 0.9 in 2028",[192,2370,2371,2374],{},[15,2372,2373],{},"CSCF_y"," — the cross-sectoral correction factor",[11,2376,2377,2378,2380],{},"CBAM_y sits on the ",[15,2379,57],{},". It shrinks the free amount you may subtract. Your emissions are\nnever touched by it.",[2291,2382,2384],{"id":2383},"what-the-difference-actually-costs","What the difference actually costs",[11,2386,2387],{},"Take 100 tonnes of imported steel, CN 7208 51 20, origin Argentina, 2026.",[11,2389,2390,2393,2394,2397,2398,2401],{},[15,2391,2392],{},"The correct way."," The published default value is 2.849 tCO₂e per tonne. The benchmark for that\nroute is 1.37. So the deductible free allocation is 0.975 × 1.0 × 1.37 = ",[15,2395,2396],{},"1.33575"," tonnes of CO₂e\nper tonne of goods, and what remains is 2.849 − 1.33575 = ",[15,2399,2400],{},"1.51325",". Across 100 tonnes that is\n151.3 certificates. At the Q2 2026 price of EUR 75.28:",[78,2403,2404],{},[11,2405,2406],{},[15,2407,2408],{},"EUR 11,391.75",[11,2410,2411,2414],{},[15,2412,2413],{},"The wrong way."," Multiply the emissions by the withdrawn share: 2.849 × 0.025 = 0.07123 tonnes per\ntonne, 100 tonnes, same price:",[78,2416,2417],{},[11,2418,2419],{},[15,2420,2421],{},"EUR 536.18",[11,2423,2424,2425,2428],{},"The same shipment, the same published inputs, a ",[15,2426,2427],{},"factor of twenty-one"," between them — and the wrong\nmethod is the one that produces the comforting number.",[11,2430,2431],{},[83,2432,2433],{},"(One honest caveat: the CSCF for 2026 has not been published by the Commission, so the 1.0 above is\nan assumption. When the real factor lands, every figure calculated on this basis moves. That is worth\nknowing before anyone books a provision against it.)",[30,2435,2437],{"id":2436},"why-the-direction-of-the-error-matters","Why the direction of the error matters",[11,2439,2440],{},"If you overstate your obligation you buy certificates you did not need. Unpleasant, recoverable.",[11,2442,2443,2444,2447],{},"Understating is a different category. Under-surrender is penalised at ",[15,2445,2446],{},"three to five times EUR 100\nper tonne of CO₂e"," (Art. 26(2)), and the penalty is assessed against the shortfall, not against your\ngood intentions. On the example above, an importer who budgeted EUR 536 against a real obligation of\nEUR 11,392 is short by about 145 certificates — and the exposure that creates is an order of\nmagnitude larger than the sum they thought they owed.",[11,2449,2450],{},"This is also why \"we'll refine the number later\" is a weaker plan than it sounds. The refinement\nusually goes upward.",[30,2452,187],{"id":186},[11,2454,2455],{},"You do not need to redo anyone's arithmetic. Three questions will tell you whether a CBAM figure was\nbuilt on solid ground.",[11,2457,2458,2461],{},[15,2459,2460],{},"1. Ask which year's column the emissions figure came from."," If the answer is \"we took the value and\napplied twenty percent\", the number is derived rather than read — and it is wrong on the compounding\nrows and on every fertiliser line.",[11,2463,2464,2467],{},[15,2465,2466],{},"2. Ask what the free-allocation factor was multiplied by."," If the answer is \"the emissions\", the\nfigure is too low, probably by a large multiple. It should have been multiplied by the benchmark.",[11,2469,2470,2473],{},[15,2471,2472],{},"3. Ask what CSCF was assumed."," If nobody can name a value, nobody has thought about it — and the\nfigure will move when the Commission publishes.",[11,2475,2476],{},"None of that requires a consultant. It requires knowing that both factors attach to something\nspecific, and asking what.",[30,2478,2480],{"id":2479},"a-note-on-getting-it-wrong","A note on getting it wrong",[11,2482,2483],{},"We are not describing these mistakes from a distance. The second one was in our own calculation for a\nwhile: we multiplied embedded emissions by the withdrawn share, exactly as described above. The\ncomment that now sits in that part of our code says so in plain language, deliberately, so nobody\nreintroduces it later.",[11,2485,2486],{},"It survived because it produced numbers that looked reasonable. That is the property that makes this\nclass of error worth writing about — a misplaced factor does not announce itself. It gives you an\nanswer, in the right units, of a believable size. The only way to catch it is to check what each\nfactor is attached to.",[217,2488],{},[11,2490,2491],{},[83,2492,2493],{},"This article explains the rules as we read them; it is not legal advice. The default values and their\nmark-up are set out in Implementing Regulation (EU) 2025\u002F2621, the free-allocation basis in\nImplementing Regulation (EU) 2025\u002F2620, and the penalty regime in Regulation (EU) 2023\u002F956 as amended.\nVerify your own position with your customs agent or the competent authority in your member state — in\nGermany, the DEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":2495},[2496,2500,2503,2504,2505],{"id":2230,"depth":225,"text":2231,"children":2497},[2498],{"id":2293,"depth":2499,"text":2294},3,{"id":2316,"depth":225,"text":2317,"children":2501},[2502],{"id":2383,"depth":2499,"text":2384},{"id":2436,"depth":225,"text":2437},{"id":186,"depth":225,"text":187},{"id":2479,"depth":225,"text":2480},"2026-08-25","Both are multiplications, and both get applied to the wrong thing. One inflates your carbon bill by a factor of twenty; the other quietly under-states it. We shipped the second mistake ourselves before we caught it.","https:\u002F\u002Fy7cuzzvjaoml1mzf.public.blob.vercel-storage.com\u002Fblog-4.webp","Three identical steel billets in a receding row on a mill floor, each one lit a little brighter than the one before it","CBAM mark-up, CBAM default values, CBAM free allocation factor, CBAM SEFA, CBAM benchmark, CBAM calculation, CBAM Standardwerte Aufschlag, CBAM Gratiszuteilung",{},{"title":2212,"description":2507},"blog\u002Fcbam-two-numbers-most-calculations-get-wrong",[245,246],"IhBZDS-ZqjrEdEObDKYu2esF6X7go5xQ2kyKgKuWqFg",{"id":2517,"title":2518,"body":2519,"date":2726,"description":2727,"extension":235,"hero":2728,"heroAlt":2729,"keywords":2730,"meta":2731,"navigation":239,"path":2732,"readingMinutes":241,"seo":2733,"stem":2734,"tags":2735,"__hash__":2736},"blog\u002Fblog\u002Fcbam-authorisation-120-days.md","The CBAM deadline nobody talks about: authorisation takes 120 days",{"type":8,"value":2520,"toc":2718},[2521,2528,2531,2534,2538,2547,2553,2557,2563,2566,2592,2599,2606,2609,2613,2620,2627,2638,2642,2645,2652,2659,2662,2664,2667,2673,2682,2691,2694,2698,2701,2708,2711,2713],[11,2522,2523,2524,2527],{},"Most CBAM coverage points at the same date: ",[15,2525,2526],{},"30 September 2027",", when the first annual declaration\nis due. It is a real deadline, and it is comfortably far away.",[11,2529,2530],{},"It is also the wrong one to worry about first.",[11,2532,2533],{},"There is a second clock, it started on 1 January 2026, and unlike the filing date it can stop your\ngoods at the border. Almost nobody writes about it, because it isn't a filing deadline — it's a\nprocessing time.",[30,2535,2537],{"id":2536},"the-rule-in-one-sentence","The rule in one sentence",[11,2539,2540],{},[15,2541,2542,2543,2546],{},"You must hold the status of authorised CBAM declarant ",[83,2544,2545],{},"before"," you cross 50 tonnes of CBAM goods in\na calendar year — and the authority has up to 120 days to decide.",[11,2548,2549,2550,2552],{},"Not 120 days before your declaration. 120 days before the ",[15,2551,1536],{}," that takes you over the line.",[30,2554,2556],{"id":2555},"why-this-catches-people-out","Why this catches people out",[11,2558,2559,2560],{},"The threshold feels forgiving. Fifty tonnes a year sounds like a lot if you have never counted, and\nthe carbon bill at 2026 phase-in rates is small enough to look like a rounding error. So the natural\nreaction is: ",[83,2561,2562],{},"we'll deal with it when we get there.",[11,2564,2565],{},"The problem is the order of operations.",[189,2567,2568,2574,2583],{},[192,2569,2570,2573],{},[15,2571,2572],{},"Every import since 1 January 2026 counts."," The 50 tonnes is cumulative across the calendar\nyear, not per shipment and not from the day you noticed.",[192,2575,2576,2579,2580,1501],{},[15,2577,2578],{},"Authorisation takes 120 calendar days"," from the day the authority receives a complete\napplication (Art. 4(1), Implementing Regulation (EU) 2025\u002F486). If they come back with questions,\nthe clock extends to ",[15,2581,2582],{},"180 days",[192,2584,2585,2588,2589,2591],{},[15,2586,2587],{},"The status has to exist before the crossing, not after."," Germany's DEHSt puts it plainly: you\nneed authorised-declarant status ",[83,2590,2545],{}," you exceed the 50-tonne threshold, to avoid an import\nban.",[11,2593,2594,2595,2598],{},"Put those together and the arithmetic is uncomfortable. ",[15,2596,2597],{},"Count 120 days forward from the day your\napplication is complete — that is the earliest date your status can exist."," Every tonne that would\ntake you past 50 tonnes before that date is a tonne you are not permitted to import.",[11,2600,2601,2602,2605],{},"By September 2026 that sum has crossed a line worth naming out loud: an application completed now is\ndecided in ",[15,2603,2604],{},"January 2027",", which is no longer inside the 2026 import year at all. If your fourth\nquarter takes you past 50 tonnes, the question is not whether the timing is tight. It has gone.",[11,2607,2608],{},"You cannot fix that retroactively. The clock has already run.",[30,2610,2612],{"id":2611},"the-safety-net-that-used-to-exist-is-gone","The safety net that used to exist is gone",[11,2614,2615,2616,2619],{},"There was a provision that softened exactly this problem. Article 17(7a) let importers with a\n",[83,2617,2618],{},"pending"," application keep importing above the threshold while they waited for a decision.",[11,2621,2622,2623,2626],{},"It only applied to applications filed ",[15,2624,2625],{},"by 31 March 2026",". That date has passed. Applying now means\nwaiting without cover.",[11,2628,2629,2630,2633,2634,2637],{},"This is the part that gets misread most often: people hear \"31 March 2026\" and conclude that\nauthorisation itself closed. It did not — ",[15,2631,2632],{},"you can still apply, any day."," What closed was the\ngrace period for importing while you wait. Losing it makes applying ",[83,2635,2636],{},"more"," urgent, not pointless.",[30,2639,2641],{"id":2640},"what-happens-if-you-cross-without-it","What happens if you cross without it",[11,2643,2644],{},"The penalty is not proportionate to the carbon. It is proportionate to the breach.",[11,2646,2647,2648,2651],{},"Crossing the threshold unauthorised is penalised at ",[15,2649,2650],{},"three to five times EUR 100 per tonne of CO₂e","\nembedded in the goods (Art. 26(2) and (2a)), reduced only where the excess is 10% of the threshold or\nless.",[11,2653,2654,2655,2658],{},"For a mid-sized steel importer that is not a rounding error. Take 200 tonnes a year of imported steel:\nroughly 440 tonnes of embedded CO₂e, so a penalty in the region of ",[15,2656,2657],{},"EUR 130,000 to 220,000"," — against\na carbon bill of well under EUR 1,000 at 2026 phase-in rates.",[11,2660,2661],{},"That ratio, somewhere between 150× and 250×, is the actual reason to care about CBAM this year. Not\nthe levy. The levy is small and will stay small for a while. The exposure comes from being on the\nwrong side of a status you could have applied for.",[30,2663,1367],{"id":1366},[11,2665,2666],{},"You do not need a consultant to work out where you stand. You need three numbers.",[11,2668,2669,2672],{},[15,2670,2671],{},"1. Add up what you have already imported this year."," Only CBAM goods — iron and steel, aluminium,\ncement, fertilisers, hydrogen, electricity — and only from outside the EU. Net mass, in tonnes, since\n1 January.",[11,2674,2675,2678,2679],{},[15,2676,2677],{},"2. Project the rest of the year."," Take your usual pattern and carry it forward. You are answering\none question: ",[83,2680,2681],{},"do we cross 50 tonnes, and roughly when?",[11,2683,2684,2687,2688,1501],{},[15,2685,2686],{},"3. Compare that date with today plus 120 days."," If your crossing date is earlier, you have a\nproblem that only gets worse by waiting, and the application should go in immediately. If it is later,\nyou have room — but less than the calendar suggests, because the 120 days only start once the\napplication is ",[15,2689,2690],{},"complete",[11,2692,2693],{},"If the honest answer to step 2 is \"no idea\", that is itself the finding. It means the number that\ndecides your legal position is one nobody in the company is tracking.",[30,2695,2697],{"id":2696},"where-this-leaves-the-2027-date","Where this leaves the 2027 date",[11,2699,2700],{},"Nothing above changes the filing deadline. The first annual declaration is still due on\n30 September 2027, certificates cannot be bought before 1 February 2027, and the definitive\ndeclaration format has not yet been published by the Commission.",[11,2702,2703,2704,2707],{},"But the evidence that declaration is made from — which goods, which origins, what mass, which\nsupplier data — is being generated ",[15,2705,2706],{},"now",", on every shipment that clears customs. That part is not\nwaiting for Brussels.",[11,2709,2710],{},"The 2027 deadline is about paperwork you will assemble. The authorisation deadline is about whether\nyou are allowed to keep importing while you assemble it.",[217,2712],{},[11,2714,2715],{},[83,2716,2717],{},"Last reviewed 10 September 2026. This article explains the rules as we read them; it is not legal\nadvice. Thresholds and penalties are set out in Regulation (EU) 2023\u002F956 as amended, and in\nImplementing Regulation (EU) 2025\u002F486.\nCheck your own position with your customs agent or the competent authority in your member state — in\nGermany, the DEHSt.",{"title":47,"searchDepth":225,"depth":225,"links":2719},[2720,2721,2722,2723,2724,2725],{"id":2536,"depth":225,"text":2537},{"id":2555,"depth":225,"text":2556},{"id":2611,"depth":225,"text":2612},{"id":2640,"depth":225,"text":2641},{"id":1366,"depth":225,"text":1367},{"id":2696,"depth":225,"text":2697},"2026-08-19","Everyone is watching the 2027 filing date. The deadline that can stop your imports is already running — you need authorised-declarant status before you cross 50 tonnes, and the decision takes up to 120 days.","https:\u002F\u002FY7CUzzVjaoML1MZf.public.blob.vercel-storage.com\u002Fblog-1.webp","Containers stacked at a European port at dusk, a single lane of them lit while the rest fall into shadow","CBAM authorised declarant, CBAM authorisation 120 days, CBAM 50 tonnes threshold, CBAM import ban, CBAM penalty, CBAM authorisation deadline, zugelassener CBAM-Anmelder",{},"\u002Fblog\u002Fcbam-authorisation-120-days",{"title":2518,"description":2727},"blog\u002Fcbam-authorisation-120-days",[246,1700],"CwpNPDyQvJrf3yRCi-Pm0giDPabpVXd3RrcABVOE1PU",{"id":2738,"title":2739,"body":2740,"date":2844,"description":2845,"extension":235,"hero":2846,"heroAlt":2847,"keywords":2848,"meta":2849,"navigation":239,"path":2850,"readingMinutes":2851,"seo":2852,"stem":2853,"tags":2854,"__hash__":2856},"blog\u002Fblog\u002Fdoes-cbam-affect-me.md","Does CBAM affect me? The goods, thresholds and origins that trigger it",{"type":8,"value":2741,"toc":2837},[2742,2745,2749,2756,2760,2763,2783,2790,2794,2801,2804,2808,2815,2818,2822,2825,2832],[11,2743,2744],{},"Most small and mid-sized importers aren't sure whether CBAM is their problem or someone else's. The\ngood news: you can usually tell in about two minutes. It comes down to three questions.",[30,2746,2748],{"id":2747},"three-questions-decide-it","Three questions decide it",[11,2750,2751,2752,2755],{},"CBAM applies to you if ",[15,2753,2754],{},"all three"," of these are true. Miss any one and it very likely doesn't.",[30,2757,2759],{"id":2758},"_1-do-you-import-one-of-the-six-goods","1. Do you import one of the six goods?",[11,2761,2762],{},"CBAM only covers six carbon-intensive product groups:",[1306,2764,2765,2768,2771,2774,2777,2780],{},[192,2766,2767],{},"Iron and steel",[192,2769,2770],{},"Aluminium",[192,2772,2773],{},"Cement",[192,2775,2776],{},"Fertilisers",[192,2778,2779],{},"Hydrogen",[192,2781,2782],{},"Electricity",[11,2784,2785,2786,2789],{},"This includes many ",[83,2787,2788],{},"processed"," products made from them — screws, tubes, structural parts and the\nlike — not just raw slabs and ingots. If nothing you import is made of these materials, you can stop\nhere: CBAM doesn't apply.",[30,2791,2793],{"id":2792},"_2-do-they-come-from-outside-the-eu","2. Do they come from outside the EU?",[11,2795,2796,2797,2800],{},"CBAM is a ",[83,2798,2799],{},"border"," mechanism. It only bites on goods brought into the EU from a non-EU country. Move\nthe same steel between two EU member states and CBAM is irrelevant — it's already inside the system.",[11,2802,2803],{},"A handful of closely-linked countries (those inside the EU's own emissions trading system) are\ntreated as inside the border too. For nearly everyone else, \"imported from outside the EU\" is the\nline that matters.",[30,2805,2807],{"id":2806},"_3-are-you-over-the-small-quantity-threshold","3. Are you over the small-quantity threshold?",[11,2809,2810,2811,2814],{},"This is the one that spares a lot of small importers. Below a ",[15,2812,2813],{},"small annual quantity — in the\nregion of 50 tonnes of CBAM goods per year"," — you fall under a de-minimis exemption and don't carry\nthe full obligation. The exact rule is set in the regulation and has been adjusted to keep the\nsmallest importers out of scope while still capturing the vast majority of emissions.",[11,2816,2817],{},"The catch: 50 tonnes of steel or aluminium is not a lot. A few containers can cross it. So \"we're\nunder the threshold\" is worth checking properly rather than assuming — especially as your volumes\ngrow.",[30,2819,2821],{"id":2820},"still-not-sure","Still not sure?",[11,2823,2824],{},"If you answered \"yes, yes, and maybe\" you're exactly the kind of importer CBAM is aimed at, and it's\nworth pinning down your precise position before a deadline does it for you. Penalties for\nunder-reporting run to several times the cost of getting it right.",[11,2826,2827,2831],{},[2054,2828,2830],{"href":2829},"\u002Fcbam-check","Run the free 2-minute check"," — three quick questions, no sign-up, and a plain answer on\nwhether CBAM applies to you.",[11,2833,2834],{},[83,2835,2836],{},"This article is a general explainer, not legal advice. Thresholds and scope are defined by the EU\nregulation and depend on your specific imports.",{"title":47,"searchDepth":225,"depth":225,"links":2838},[2839,2840,2841,2842,2843],{"id":2747,"depth":225,"text":2748},{"id":2758,"depth":225,"text":2759},{"id":2792,"depth":225,"text":2793},{"id":2806,"depth":225,"text":2807},{"id":2820,"depth":225,"text":2821},"2026-07-24","A quick way to tell whether the EU's carbon border rules apply to your imports — the six goods categories, the small-quantity exemption, and why 'made outside the EU' is the deciding factor.","https:\u002F\u002FY7CUzzVjaoML1MZf.public.blob.vercel-storage.com\u002Fblog-2.webp","Coils of rolled steel in a warehouse, one lit brightly while the rows behind recede into darkness","does CBAM affect me, CBAM threshold, CBAM goods, CBAM exemption, CBAM 50 tonnes, am I affected by CBAM, CBAM small importer",{},"\u002Fblog\u002Fdoes-cbam-affect-me",4,{"title":2739,"description":2845},"blog\u002Fdoes-cbam-affect-me",[2855,1960],"CBAM basics","ktq9LbyIX2-Xyg6S3VLZLXtzkwDcvIstLvDjdYDmlZ0",{"id":2858,"title":2859,"body":2860,"date":3014,"description":3015,"extension":235,"hero":3016,"heroAlt":3017,"keywords":3018,"meta":3019,"navigation":239,"path":3020,"readingMinutes":3021,"seo":3022,"stem":3023,"tags":3024,"__hash__":3025},"blog\u002Fblog\u002Fwhat-is-cbam.md","What is CBAM? A plain-English guide for EU importers",{"type":8,"value":2861,"toc":3007},[2862,2865,2869,2876,2879,2883,2889,2915,2918,2922,2925,2947,2950,2954,2957,2986,2989,2993,2996,3002],[11,2863,2864],{},"If you import steel, aluminium, cement, fertiliser, hydrogen or electricity into the EU, you have\nprobably had CBAM land in your inbox — usually as a forwarded email with a deadline and a lot of\nacronyms. This is the plain-English version: what CBAM is, who it touches, and what actually\nchanges for you.",[30,2866,2868],{"id":2867},"the-one-sentence-version","The one-sentence version",[11,2870,2871,2872,2875],{},"CBAM — the ",[15,2873,2874],{},"Carbon Border Adjustment Mechanism"," — makes importers of certain carbon-intensive\ngoods pay for the emissions produced making those goods, so that imports face a carbon cost\ncomparable to what EU producers already pay under the EU Emissions Trading System.",[11,2877,2878],{},"The goal is simple even if the paperwork isn't: stop companies from dodging Europe's climate rules\nby moving production abroad and importing the result.",[30,2880,2882],{"id":2881},"which-goods-cbam-covers","Which goods CBAM covers",[11,2884,2885,2886,2888],{},"CBAM does ",[15,2887,1114],{}," apply to everything you import. It covers six groups of goods where production is\nespecially carbon-intensive:",[1306,2890,2891,2895,2899,2903,2907,2911],{},[192,2892,2893],{},[15,2894,2767],{},[192,2896,2897],{},[15,2898,2770],{},[192,2900,2901],{},[15,2902,2773],{},[192,2904,2905],{},[15,2906,2776],{},[192,2908,2909],{},[15,2910,2779],{},[192,2912,2913],{},[15,2914,2782],{},[11,2916,2917],{},"If none of your imports fall into these categories, CBAM almost certainly doesn't apply to you. If\nsome do, the next question is how much and from where — more on that below.",[30,2919,2921],{"id":2920},"two-phases-first-you-report-then-you-pay","Two phases: first you report, then you pay",[11,2923,2924],{},"CBAM rolled out in two stages, and it's easy to confuse them:",[189,2926,2927,2937],{},[192,2928,2929,2932,2933,2936],{},[15,2930,2931],{},"The transitional phase (2023–2025)"," was ",[83,2934,2935],{},"reporting only",". Importers filed quarterly reports on\nthe emissions embedded in their goods, but paid nothing. It was a dry run — for companies and for\nthe Commission.",[192,2938,2939,2942,2943,2946],{},[15,2940,2941],{},"The definitive regime (from 2026)"," is where it gets real. Importers now have to buy and\nsurrender ",[15,2944,2945],{},"CBAM certificates"," covering the emissions embedded in what they bring in. The price\nof a certificate tracks the EU carbon price, and a shrinking free allocation is phased out over\nthe following years.",[11,2948,2949],{},"In other words: the era of \"just report it\" is over. From 2026 there's a number attached, in euros.",[30,2951,2953],{"id":2952},"what-you-actually-have-to-do","What you actually have to do",[11,2955,2956],{},"Stripped of the jargon, compliance comes down to a handful of steps repeated for each import:",[1306,2958,2959,2966,2973,2980],{},[192,2960,2961,2962,2965],{},"Work out the ",[15,2963,2964],{},"right customs classification"," for the goods.",[192,2967,2968,2969,2972],{},"Establish the ",[15,2970,2971],{},"embedded emissions"," — ideally actual data from your supplier, with default values\nas a fallback.",[192,2974,2975,2976,2979],{},"Calculate the ",[15,2977,2978],{},"certificate obligation"," for the emissions that aren't covered by free allocation.",[192,2981,2982,2983,2985],{},"Track the ",[15,2984,1700],{}," and file an annual declaration.",[11,2987,2988],{},"None of it is conceptually hard. It's just detailed, unforgiving of small errors, and repeated every\ntime you import — which is exactly why it eats time.",[30,2990,2992],{"id":2991},"where-tarify-fits","Where tarify fits",[11,2994,2995],{},"tarify does the expert part in the background. You connect your files, it reads your invoices, works\nout whether you're even over the threshold, calculates what you'll owe in plain euros against the\nactual legal text, and prepares the declaration for you to review and submit. You never have to\nbecome a CBAM expert to stay compliant.",[11,2997,2998,2999,3001],{},"Not sure whether any of this applies to you? ",[2054,3000,2830],{"href":2829}," — no sign-up,\nno jargon, just a plain answer.",[11,3003,3004],{},[83,3005,3006],{},"This article is a general explainer, not legal advice. Your exact obligations are set by the EU\nregulation and depend on your specific imports.",{"title":47,"searchDepth":225,"depth":225,"links":3008},[3009,3010,3011,3012,3013],{"id":2867,"depth":225,"text":2868},{"id":2881,"depth":225,"text":2882},{"id":2920,"depth":225,"text":2921},{"id":2952,"depth":225,"text":2953},{"id":2991,"depth":225,"text":2992},"2026-07-21","The EU's Carbon Border Adjustment Mechanism, explained without the jargon — what it is, which goods it covers, the 2026 shift from reporting to paying, and what importers actually have to do.","https:\u002F\u002FY7CUzzVjaoML1MZf.public.blob.vercel-storage.com\u002Fblog-3.webp","A cargo ship being unloaded under a grey European sky, gantry cranes reaching over stacked containers","CBAM, Carbon Border Adjustment Mechanism, EU CBAM, CBAM 2026, CBAM certificates, CBAM importer, carbon border tax, what is CBAM",{},"\u002Fblog\u002Fwhat-is-cbam",5,{"title":2859,"description":3015},"blog\u002Fwhat-is-cbam",[2855,246],"rxgZzhPWE70hsWP6B78OiYr9iePn2yYzhg73iHmhSDs",1790002810672]