Customs

Carbon tariffs, from September the list of Cbam certifiers

From the European Commission the Faq with guidance for operators. Mandatory rules for those importing more than 50 tonnes net mass per year

by Fulvio Liberatore and Benedetto Santacroce

29 May 2026

3' min read

Translated by AI

Versione italiana

Key points

What the Faq stipulates
Collection of emission data
Cbam Certificate Procurement and Management

3' min read

Translated by AI

Versione italiana

Five months before the entry into force of the final Carbon border adjustment mechanism (Cbam), the European Commission provides guidance to operators with some Faqs. The document announces that from September 2026 there will be a list of accredited certifiers who must verify the actual emission data for Cbam products - fertilisers, hydrogen, electricity, cement, aluminium and iron and steel -; warns operators about using other parties than manufacturers for the acquisition of real data; provides the map of exemptions linked to subjective requirements or special customs regimes.

What the Faq provides

In particular, the Faqs, published on 27 May 2026, attempt in a structured manner to create a compliance map both for obliged operators (importers of Cbam goods in excess of 50 tonnes net mass per year) and for those who can avoid declaratory obligations.

Importers who are certain not to exceed 50 tonnes net overall of Cbam goods will only have to declare this specific condition in their declarations for release for free circulation using code Y137.

For those who import or presume to import Cbam goods in excess of 50 tonnes globally (i.e. summing up all imported Cbam goods), or who importelectricity or hydrogen (without any minimum limit), or who have decided to act as indirect representatives, a number of immediate obligations are triggered and, above all, they must already now equip themselves accordingly in order to comply with the requirements of the legislation.

First of all, in addition to the different exemption codes to be used, if any, in customs declarations (goods intended for specific uses or originating in certain territories exempt from Cbam obligations), the obliged parties will have to take on the status of Authorised Cbam Declarant through the procedure established in Italia by the Ministry of the Environment and Energy Security: without the status, to which a specific account corresponds, it will not be possible to release the Cbam goods for free circulation.

The collection of emission data

The Faq clarify, in detail, how to obtain actual data on emissions related to the production of Cbam goods, reiterating some key definitions (such as embedded emissions, indirect emissions, precursor-related emissions, simple or complex goods) and, above all, making it clear that the certification of emissions will have to be carried out by accredited Cbam verifiers and the first list of those who should have obtained accreditation should be made available in September 2026 (Section 5.12).

Only operators producing Cbam goods in third countries should verify emissions: Faqs alert importers to the need to obtain verified emissions information exclusively from operators in third countries producing Cbam goods. Should others offer verification services to importers, they should be considered 'scams' (cheating). If actual emission values are available but have not been verified, default values (those already published by the Commission in Regulation 2025/2061) must be used.

Of particular relevance are the instructions concerning the calculation of emissions or the total removal from the Cbam perimeter for the numerous cases related to special procedures: from transit (normally totally exempt) to outward processing of Union goods (separating the case of goods of Union origin from that of goods not originating in the Union, but previously released for free circulation), to temporary admission and treatment of goods passing through the inward processing procedure.

Purchase and Management of Cbam Certificates

Finally, the Faqs illustrate the mechanism of purchase and management of Cbam certificates (through the Common central platform) and explain the calculation of the actual Cbam debt, from which the corresponding free allocation quotas of the Ets guaranteed for goods produced in the Union are to be deducted, in addition to thecarbon price possibly paid in third countries. In the case of negative results, they will unfortunately be reset to zero and cannot be used to offset other current or future Cbam debts.