Does EU CBAM apply to packaging exports?

Not directly. CBAM covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Packaging and most finished goods are outside its scope today.

Are small EU importers exempt from CBAM?

Yes, if their imports of CBAM goods, excluding electricity and hydrogen, stay at or below 50 tonnes a year. Above that, all of that year's imports are in scope.

When does the EU importer pay for CBAM?

CBAM certificates go on sale on 1 February 2027. The declaration and surrender for 2026 imports are due by 30 September 2027.

What CBAM data does a non-EU producer send?

Embedded emissions per tonne for each CN code and installation, verified by an accredited verifier. Without verified data the importer must use default values, which are usually higher.

EU regulation guides

EU CBAM for non-EU exporters

The Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956 as simplified by Regulation (EU) 2025/2083, puts a carbon price on certain imports. Your EU buyer pays it; your emissions data sets how much.

Applies now · Last reviewed 22 October 2026 · General information, not legal advice

Is EU CBAM live?

Yes. The definitive period began on 1 January 2026, so importers above the threshold must be authorised CBAM declarants and will pay for the embedded emissions of 2026 imports.

Which goods are covered?

Cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. A proposal from December 2025 to add around 180 downstream steel and aluminium products was still in negotiation in October 2026, with scope and start date not settled.

Key dates and thresholds

When	What happens
1 Jan 2026	Definitive period starts. A 50-tonne annual threshold per importer replaces the old €150 consignment rule (electricity and hydrogen excluded).
1 Feb 2027	Certificates go on sale, priced for 2026 imports at the quarterly EU ETS average.
30 Sep 2027	First annual declaration and certificate surrender, for 2026 imports.
From 2027	Declarants must hold certificates for at least 50% of year-to-date embedded emissions each quarter.

Who carries the obligation?

The authorised CBAM declarant: the EU importer, or its indirect customs representative. The non-EU producer has no direct obligation, but without its data the importer must use default values, which usually cost more.

What a non-EU producer gives the EU buyer

Embedded direct emissions in tCO2e per tonne for each good by CN code, plus indirect emissions where they count.
The installation's identity and the production route.
Verification by an accredited verifier, if actual values are to replace defaults.
Evidence of any carbon price actually paid in the country of origin.

How Truo handles CBAM

For CBAM goods, Truo keeps the installation's emissions data and verification report on the trade record against each order line and CN code, so the buyer's declarant has what they need without chasing it. The compliance agent flags lines with no verified data before shipment.

Sources

Exporting to the UK as well? See UK CBAM, which starts on 1 January 2027.