1 January 2026 – CBAM definitive period begins. Importers must purchase CBAM certificates for covered goods.
31 March 2026 – Deadline for authorized declarant status. Applications submitted after this date cannot be used for customs clearance while pending approval.
1 January 2028 – CBAM expands to approximately 180 downstream products. Anchor chains will be formally included.
From 1 January 2028, CBAM will expand to approximately 180 downstream products, including:
Machinery and hardware
Vehicle components and parts
Metal fabrications
Domestic appliances
Anchor chains (HS 731581 / 731582)
The EU selected these products because of their high steel / aluminium content – on average 79% – and high risk of carbon leakage.
For anchor chain products, the carbon cost will be calculated based on the steel content only, not the entire manufacturing process.
Important: The 50 tonne de minimis threshold remains. Importers with annual imports under 50 tonnes are exempt, but this exemption cannot be used to split orders artificially.
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Before CBAM, steel product exports competed on three dimensions: price, quality and delivery time.
Now there is a fourth dimension: carbon.
Under the new rules:
Lower carbon emissions give a competitive advantage
Carbon data must be third party verified
Verified data must travel with the product – from steel mill to anchor chain factory to your customer
This is not a test. It is a permanent rule change.
Note: The cost difference between actual data and default values is significant. We will cover this in detail in our next article.
Since 1 January 2026, EU customs have begun strictly verifying importers’ “authorized declarant” status.
What this means: If your customer has not yet obtained formal authorization, their goods may face detention at port. Customs declarations without proper authorization codes are being rejected at the border.
The authorization process can take up to 120 days. Please confirm your EU customer's status as early as possible.
We are actively preparing SGS-verified carbon data for our anchor chain products (HS 731581 and HS 731582). We have been working on carbon management since 2023.
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