CBAM goes live 1 Jan 2026: authorisation deadline 31 March
The EU Carbon Border Adjustment Mechanism (CBAM) enters its operational phase on 1 January 2026. Importers of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen exceeding 50 tonnes must have submitted an authorisation application before the import date, with a final deadline of 31 March 2026. Failure to do so risks disruptions, delays, and penalties. The EU TAXUD has published a quick-start guide and sector-specific guidance to help affected importers prepare.
Photo: Miguel Á. Padriñán / PexelsThe EU Carbon Border Adjustment Mechanism (CBAM) transitions from its transition phase to live operation on 1 January 2026, according to an official reminder from EU TAXUD (Directorate-General for Taxation and Customs Union) published 23 December 2025.
Starting that date, importers of specified goods face a new mandatory authorisation requirement. As the authority states:
Those importing more than 50 tonnes of cement, iron and steel, aluminium, fertiliser, as well as all importers of electricity or hydrogen need to have submitted an application or received an authorisation at the time of import.
The scope covers the core CBAM commodities: HS Chapters 25 (cement), 72 (iron and steel), 76 (aluminium), fertilisers, plus electricity and hydrogen. Notably, importers of electricity and hydrogen face the requirement regardless of volume; for the solid commodities (cement, steel, aluminium, fertilisers), the threshold is 50 tonnes per shipment.
Critical deadline: All applications must be submitted by 31 March 2026 at the latest. This applies to "all concerned import companies." The EU warns that importers who have not already applied "need to act fast now to avoid risking disruptions, delays, or penalties."
The implications are severe: missing the deadline or failing to obtain authorisation before goods arrive will trigger customs delays, hold-ups, and potential financial penalties. Given the lead time between now and end-Q1 2026, importers should prioritise their applications immediately.
EU TAXUD has published supporting materials, including a Quick Guide (available as a PDF download) and sector-specific guidance accessible on the official CBAM webpage. These resources clarify the application process, required documentation, and obligations by commodity type.
What this means for shippers
If you import cement, steel, aluminium, fertilisers, electricity, or hydrogen into the EU—especially above 50 tonnes—you must apply for CBAM authorisation immediately. Do not wait until January 2026. Missing the 31 March 2026 deadline exposes you to customs delays, rejection of entries, and penalties. Consult EU TAXUD's Quick Guide now, confirm your HS chapter classification and embedded-emissions reporting obligations, and submit your authorisation application without delay. /cbam
