We sell steel parts to an EU defence buyer. Are military goods exempt from CBAM?
Usually not. Article 2(3)(c) of the CBAM Regulation exempts only goods moved or used in military activities under Article 1(49) of Delegated Regulation (EU) 2015/2446, which means movements between military forces. The EU's CBAM Q&A 1.13 says goods a company sells to EU military forces are subject to CBAM.
What the exemption covers
- Goods moved between military forces, for example between NATO bases, in the activities Article 1(49) lists.
- These movements are declared on the NATO or EU Form 302, and goods declared that way are not subject to CBAM.
- If such goods are declared another way, the importer should state in the customs declaration that Article 2(3)(c) applies.
What does not qualify
- A commercial sale by your company to an EU armed force.
- Goods imported by or for an EU country's military authorities but not for the activities in Article 1(49).
What to prepare
Treat the order like any other CBAM shipment. Whoever imports it, a defence ministry or a prime contractor, will ask for the CN code, net mass and the embedded emissions of your installation, or will fall back on EU default values.
What Senseible does here
Senseible reads your fuel and electricity bills into the installation records a defence importer will ask for, the same as for any EU buyer. It does not decide customs status.
Sources: European Commission, CBAM Questions and Answers (15 October 2026), question 1.13, CBAM Regulation (EU) 2023/956, consolidated
Last reviewed 2026-11-01.