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  • CBAM basics
  • am I affected

Does CBAM affect me? The goods, thresholds and origins that trigger it

4 min read

Most small and mid-sized importers aren't sure whether CBAM is their problem or someone else's. The good news: you can usually tell in about two minutes. It comes down to three questions.

Three questions decide it

CBAM applies to you if all three of these are true. Miss any one and it very likely doesn't.

1. Do you import one of the six goods?

CBAM only covers six carbon-intensive product groups:

  • Iron and steel
  • Aluminium
  • Cement
  • Fertilisers
  • Hydrogen
  • Electricity

This includes many processed products made from them — screws, tubes, structural parts and the like — not just raw slabs and ingots. If nothing you import is made of these materials, you can stop here: CBAM doesn't apply.

2. Do they come from outside the EU?

CBAM is a border mechanism. It only bites on goods brought into the EU from a non-EU country. Move the same steel between two EU member states and CBAM is irrelevant — it's already inside the system.

A handful of closely-linked countries (those inside the EU's own emissions trading system) are treated as inside the border too. For nearly everyone else, "imported from outside the EU" is the line that matters.

3. Are you over the small-quantity threshold?

This is the one that spares a lot of small importers. Below a small annual quantity — in the region of 50 tonnes of CBAM goods per year — you fall under a de-minimis exemption and don't carry the full obligation. The exact rule is set in the regulation and has been adjusted to keep the smallest importers out of scope while still capturing the vast majority of emissions.

The catch: 50 tonnes of steel or aluminium is not a lot. A few containers can cross it. So "we're under the threshold" is worth checking properly rather than assuming — especially as your volumes grow.

Still not sure?

If you answered "yes, yes, and maybe" you're exactly the kind of importer CBAM is aimed at, and it's worth pinning down your precise position before a deadline does it for you. Penalties for under-reporting run to several times the cost of getting it right.

Run the free 2-minute check — three quick questions, no sign-up, and a plain answer on whether CBAM applies to you.

This article is a general explainer, not legal advice. Thresholds and scope are defined by the EU regulation and depend on your specific imports.