Our steel was made in 2025 but reaches the EU in 2026. Does CBAM still apply?
Yes. The Carbon Border Adjustment Mechanism (CBAM) applies to every import released for free circulation in the EU from 1 January 2026, whenever the goods were made or the contract signed. For 2026 imports the reporting period is set to 2026, so your buyer needs your 2026 figures, or the default value if there are none.
The date that decides it
The Commission's CBAM Questions and Answers, question 5.20, is blunt: CBAM applies to all imports of CBAM goods into the EU from 2026 onwards, regardless of when the goods were produced or when the sales contract was concluded.
What matters is the moment the EU customs authority accepts the declaration that releases the goods for free circulation. Not the day you shipped, invoiced or made the coil.
Which year's figures your buyer uses
For goods imported during 2026, the reporting period is legally set to 2026, even if the goods were made in earlier years. This spares your buyer from proving a production date for every tonne.
The Q&A also says that, for 2026, emissions data for goods produced before 1 January 2026 cannot be given, because there was no CBAM verification and no accredited CBAM verifier at the time. Your buyer's declaration for 2026 imports is due by 30 September 2027. If no actual verified emissions for 2026 exist by then, default values must be used.
What to do about stock made in 2025
- Do not build a separate 2025 figure. It cannot be used for 2026 imports.
- Ask each buyer for the date customs accepted its declaration. That date, not your bill of lading date, sets the period.
- Keep complete 2026 fuel, power and production records from 1 January, because 2026 is the year your buyer will need.
- Goods released before 2026 fell under the earlier reporting-only period, which had no payment attached.
Example: a coil made in December 2025
- Contract signed: 10 October 2025
- Coil made: 12 December 2025
- Loaded at the port: 27 December 2025
- EU customs accepts the release declaration: 14 January 2026
- Result: CBAM applies. Reporting period: 2026. Your buyer needs your verified 2026 figure by its declaration due 30 September 2027, or uses the default value
- Had customs accepted the declaration on 30 December 2025, the import would have fallen in the earlier reporting-only period
Dates are an example. Customs acceptance dates differ for every shipment.
What Senseible does here
Senseible's CBAM calculator shows what a default value means for your buyer on a shipment, and the CBAM suite builds the file from your 2026 bills and invoices as the year's records come in. It does not file declarations.
- Which year's verification report applies
- Corrected default values, July 2026
- CBAM report and calculator
Last reviewed 2026-11-04. Re-check questions 5.17 and 5.20 when the Commission updates the Q&A.