CBAM liabilities have been accruing since 1 January 2026. Quantify them before the first surrender.

The definitive regime applies to imports made this year; certificates go on sale on 1 February 2027 and the first declaration and surrender fall due on 30 September 2027. Importers near the 50-tonne threshold, groups importing through indirect customs representatives, and anyone importing electricity have decisions to take now — on declarant status, supplier data and cash.

Who it is for

• Industrial importers of iron and steel, aluminium, cement, fertilisers and hydrogen goods who have not yet quantified 2026 exposure.
• Traders and groups close to the 50-tonne cumulative threshold, or above it in some months and not others.
• Indirect customs representatives asked to act as declarant for non-EU importers.
• Energy utilities and traders importing electricity, where the default-value treatment and the actual-emissions conditions decide the bill.
• CFOs who need certificate cost in the 2027 budget and the ETS price exposure explained.

What you receive

• Exposure assessment — goods, volumes and embedded emissions by supplier; position against the threshold; certificate cost under ETS price scenarios; treatment of electricity imports and guarantees of origin.
• Declarant readiness file — authorisation application support, registry set-up, internal responsibilities, data flows from suppliers.
• Supplier data protocol — what to ask installations for, in which format, and what to do when default values are the only option.
• Certificate budgeting model — purchase timing, surrender schedule, cash impact.

How it runs

Indicatively three to five weeks.

1. Scoping call. Customs data, product range, suppliers, existing ETS exposure.
2. Engagement letter. Exposure assessment and readiness file as deliverables.
3. Delivery. Data extraction → embedded-emissions mapping → threshold and cost analysis → readiness actions.
4. Review session with finance and customs; handover of the model.

Where the text and practice diverge

• The 50-tonne exemption (Regulation (EU) 2025/2083) is one cumulative figure across all CBAM goods per importer per calendar year, and electricity and hydrogen are outside it. Summaries that read it as "per product category" are wrong.
• Authorised declarant status has been required since 1 January 2026; applicants by 31 March 2026 were tolerated provisionally. National authorities differ on processing time and on how much data-quality leniency survives from the transitional period.
• For electricity, default values apply unless the actual-emissions criteria in Annex IV are met — a power purchase agreement, firm interconnection nomination, a direct contractual link and traceability. Few importers meet all four; the ones that do save materially.

Next step

CBAM exposure checklist — sent by email on request — or book a 20-minute scoping call.