Carbon Border Adjustment Mechanism (CBAM)

After a reporting-only transitional period from October 2023 to December 2025, the definitive regime began on 1 January 2026. Importers bringing in more than 50 tonnes of covered goods a year must hold authorised CBAM declarant status, file an annual declaration by 30 September of the following year, and surrender CBAM certificates for embedded emissions. Certificate sales start in February 2027 for 2026 imports. Importers below the 50 tonne threshold are exempt, except for electricity and hydrogen.

CBAM matters to fulfillment operators mainly as a cost and paperwork issue on imported steel and aluminium equipment and goods. Pallet racking, shelving, steel fasteners and aluminium products can fall under covered tariff codes, so a 3PL or brand importing them into the EU above the 50 tonne threshold needs declarant status and supplier emissions data. For example, a 3PL fitting out a new Dutch warehouse with Chinese-made steel racking should ask the supplier for verified emissions data and check whether the importer of record will exceed 50 tonnes in 2026.

• Landed CostTotal cost to get a product ready to sell
• Importer of RecordIORParty legally responsible for an import
• Harmonized System CodeHS CodeSix-digit international product code

• EU ETS Extended to Shipping2024 · EU carbon allowances required for ship emissions
• Union Customs Code (UCC)2013, applied 2016 · EU's core customs law for imports, exports and transit
• ANSI MH16.11974, current edition 2023 · US specification for steel storage rack design

1. European Commission: Carbon Border Adjustment Mechanism taxation-customs.ec.europa.eu
2. Regulation (EU) 2023/956 (EUR-Lex) eur-lex.europa.eu