Aktuálně k CBAM – dovoz už jen s povolením a kolik to bude stát?

As of 1 January 2026, the definitive CBAM period has started, introducing the obligation to purchase CBAM certificates and requiring importers to obtain the authorized CBAM declarant status. Those who submitted their application by 31 March, 2026, may continue importing CBAM goods even if importers have not yet received a decision from the customs authority granting this status.

However, from 1 April 2026, the customs authority will no longer release CBAM goods into free circulation without the required authorization.

We recommend importers use the remainder of 2026 to communicate with their suppliers to determine what emissions data the supplier can provide, particularly whether it will based on actual emission values or if the importer will have to rely on default emission values. Using actual emission values can have a significant positive impact on the overall financial cost of importing CBAM goods in the form of purchasing CBAM certificates. These certificates will be available for purchase from February 2027, exclusively through the European Commission’s central platform.

Since CBAM certificates will also be purchased to cover the emission intensity of goods imported in 2026, importers should already calculate the expected costs. The calculation must consider the possible use of actual values based on discussions with specific suppliers.

Below we illustrate how the use of default values versus actual emission values might differ for specific goods. For the purpose of the example, we selected the import of non-alloy steel wires (CN 7217 10) from China for the year 2026. In subsequent years, both the overall burden and the difference between using actual and standard values will increase.

1)      Example calculation for 2026 using default values

The default value for 2026 is 3.486 tCO₂/t. Assuming the steel wires are produced using blast furnace (BF/BOF) process, applying the relevant CBAM benchmark (reference value) and CBAM factor (reduction coefficient) for 2026 of 97.5% reduces this value to 2.156 tCO₂/t. In other words, each tonneof imported wire will require payment for emissions at this level, which at the current carbon permit price of EUR 72/t results in an additional cost of approximately EUR 155 per tonne of imported wire. Any further discount in the form of carbon prices paid by the manufacturer in the third country cannot be applied when using default emission values.

2)      Example calculation for 2026 using actual values

Assuming the actual emissions provided by the manufacturer (including emissions from precursors used by the manufacturer, for simplicity) are 1.84 tCO₂/t and the manufacturer uses the same BF/BOF process. Additionally, a carbon price of EUR 13 per tonne of CO₂ applies in China. Using the relevant CBAM benchmark, CBAM factor, and accounting for the carbon price paid in the third country, the emission payment can be reduced to 1.471 tCO₂/t. The additional cost would thus be EUR 106 per tonne of imported wire.

The potential saving of EUR 49/t in this model example must always be assessed in the context of additional costs that may be associated with using actual emission values on the manufacturer’s side. Manufacturers may attempt to pass some costs (e.g., for an independent emissions verifier) onto the importer.

We would be pleased to discuss CBAM obligations and their financial impact on your business in more detail and assist with next steps.

Authors:
Jakub Kašuba
Anna Běhounková