Senseible

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

What does not qualify

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.