Do product samples we send to an EU buyer for testing fall under CBAM?
No, if the samples are declared for temporary admission and not released for free circulation. CBAM applies only to goods released for free circulation in the EU. The Commission's Q&A names non-EU samples sent for testing. Goods that are in transit through the EU are also outside it.
The rule
Only goods released for free circulation in the EU are subject to CBAM. Goods declared for temporary admission, for example under Article 95 of Council Regulation (EC) No 1186/2009, are not. The Q&A gives samples of non-EU origin sent for testing as an example.
Goods passing through
The same Q&A answers the transit question: goods that only cross the EU on the way elsewhere do not have to be declared under CBAM.
What to settle before shipping
- Ask your buyer or its customs agent which customs procedure the sample will use.
- If the buyer plans to clear the lot as a normal import, treat it as an ordinary CBAM shipment and ask for the data the buyer will need.
- Keep the customs paperwork showing temporary admission with your export file.
What the Q&A does not say
It does not set a weight limit for samples. The test is the customs procedure, not the size of the parcel.
What Senseible does here
Senseible does not handle customs procedures. It can prepare the emissions record for a product line if a sample turns into a commercial lot that is released for free circulation.
Sources: European Commission, CBAM Questions and Answers (definitive period)
Last reviewed 2026-11-04.