CBAM Transitional Period Has Ended: What Importers Must Do Now

The CBAM transitional period, which ran from October 2023 to December 2025, required importers to submit quarterly emissions reports without yet purchasing certificates. That period is now closed. From 1 January 2026, the full CBAM regime applies.

What has changed:Importers of in-scope goods — steel, aluminium, cement, fertilisers, hydrogen, and electricity — must now hold a sufficient number of CBAM certificates to cover the embedded emissions in their imports. Certificates must be purchased via the CBAM Registry and surrendered annually, with the first surrender deadline falling at the end of May 2027 for the 2026 reporting year.

Authorised declarant status:Only businesses registered as Authorised Declarants on the CBAM Registry may legally import CBAM-covered goods into the EU. UK businesses importing these goods into EU member states must hold this status. Registration applications are processed by the competent authority in the EU member state where the goods first enter.

What to do if you have not yet registered:Begin the authorised declarant registration process immediately. Processing times vary by member state but typically run to four to eight weeks. Importing without declarant status after 1 January 2026 may result in penalties under Article 26 of Regulation 2023/956.

If you are unsure whether your imports are in scope or need support with registration, contact us for an initial assessment.

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