Our product has an EU duty suspension. Does that exempt it from CBAM?
No. The EU's CBAM Q&A 7.8 says tariff suspensions, such as those under Council Regulation (EU) 2023/2890, have no effect on CBAM obligations. Zero customs duty on your goods still leaves your EU importer declaring their embedded emissions and paying for them in certificates.
Two separate tests
- Customs duty depends on the tariff rate, any suspension and the goods' origin.
- CBAM depends on whether the CN code is listed in Annex I of the CBAM Regulation and the goods are released for free circulation in the EU.
What does change the importer's position
- Goods whose CN code is not in Annex I.
- Imports below 50 tonnes a year of goods other than hydrogen and electricity, counted by net mass on the customs declaration. Below that, the importer does not need to be an authorised declarant.
In your quote
Show CBAM as its own line, apart from duty. Offer your installation's actual data, so the importer is not left with the EU default values and their mark-up.
What Senseible does here
Senseible's CBAM cost calculator works out the CBAM cost of covered goods for each year from 2026 to 2034, kept apart from customs duty, so you can quote both.
Sources: European Commission, CBAM Questions and Answers (15 October 2026), question 7.8, with 1.1 and 4.30 on the 50-tonne threshold, CBAM Regulation (EU) 2023/956, consolidated
Last reviewed 2026-11-01.