CBAM frequently asked questions

The threshold applies to the importer, not the producer. It looks at the total net mass of CBAM goods each EU importer imports in a calendar year. Electricity and hydrogen are excluded. If your buyer is above it, they become an authorised declarant and declare embedded emissions, and they ask you for the data. Legal basis: 2023/956 Art. 2a and Annex VII.

Embedded emissions declared from actual data must be verified by an accredited verifier. The verifier is accredited by a national accreditation body in the EU. A physical site visit is required in the first verification year, then at least every two years. Default values need no verification, but they carry a mark-up. Legal basis: 2023/956 Art. 8(1); 2025/2546 Art. 2-3; Commission Guidance No. 2.

CBAM allows a deduction for a carbon price effectively paid in the country of origin (2023/956 Art. 9). The implementing rules for this deduction were not adopted as of 1 October 2026. In the Turkish ETS pilot period allocation is fully free, so no payment to deduct is expected for the pilot years. The real overlap is data: Turkish ETS monitoring and CBAM installation monitoring draw largely on the same invoices.

Your data is in your company's account, separated per company in the database. Evidence files are stored encrypted. You grant access: admin, data entry, viewer and consultant roles. Two-step login and an audit log are on. Your EU buyer sees only the summary you share. We will publish the hosting region on this page before launch.

The buyer sees a summary: product and CN code, period, embedded emissions per product and the method used. The full file and evidence go only to the verifier. The Commission's O3CI portal works the same way: the declarant sees only the summary. The summary report content is set out in 2025/2547 Annex IV 1.2.

Cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, by CN code (2023/956 Annex I). The first release of CBAMPass focuses on producers processing iron, steel and aluminium.

Default values are set by country and CN code, and a mark-up is added that rises each year: 10% in 2026, 20% in 2027, 30% from 2028. In addition, all emissions above the benchmark need certificates from 2026. For an installation with low actual emissions, verified data closes this gap.

Yes. The Commission's guidance for non-EU operators says quantities can be set from purchase records and year-end stock counts as well as from meters. Emission factors can come from the national inventory or the standard values in the methodology regulation. Legal basis: Commission Guidance No. 2.

The first annual declaration and certificate surrender, for 2026 imports, is on 30 September 2027. If actual data is used, verification must be finished before then. Legal basis: 2023/956 Art. 6(1), Art. 22(1).

No. A rule-based engine produces the numbers. AI only reads documents and suggests CN codes and column mappings. Each suggestion becomes data only after you approve it.