Senseible

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

Example: a coil made in December 2025

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.

Sources: European Commission, CBAM Questions and Answers (updated 15 October 2026), questions 1.2, 5.17 and 5.20

Last reviewed 2026-11-04. Re-check questions 5.17 and 5.20 when the Commission updates the Q&A.