How to Lower CBAM Costs as an Importer in Germany

Published 2026-10-13.

For a German steel trader, fastener importer or aluminium profile buyer, CBAM stopped being a reporting exercise on 1 January 2026. Imports of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity now need an authorised CBAM declarant, and the declarant will buy certificates for the embedded emissions in what it brought in.

In Germany, authorisation and oversight sit with DEHSt, the German Emissions Trading Authority at the Federal Environment Agency. Importers who applied by 31 March 2026 could keep importing while their application was assessed. Importers below 50 tonnes of covered goods a year, excluding electricity and hydrogen, are exempt.

Certificate sales for 2026 imports start in February 2027, and the first annual declaration is due by 30 September 2027. The question is how to make that bill smaller.

The three levers

1. Replace default values with actual supplier data. If the supplier cannot provide verified emissions for its installation, the declarant uses EU default values. For steel, aluminium, cement and hydrogen those carry a mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028. Default values are set to be cautious, so measured data from an efficient plant is usually lower. Getting it means asking suppliers early, because they need a monitoring plan and verification.

2. Credit the carbon price paid at origin. CBAM lets the declarant deduct a carbon price effectively paid in the country of production, when it is documented. That matters for suppliers in countries with carbon pricing, such as South Africa's carbon tax or Turkey's emissions trading system, whose first obligations apply to 2027 emissions.

3. Choose suppliers and routes on emissions as well as price. For steel, the production route changes the embedded emissions several times over. Scrap-based electric arc steel is usually far lower than blast-furnace steel. A small price premium on low-emission material can be cheaper once certificates are counted.

What to ask suppliers for now

The installation's name and location, and the production route for each product.
Specific embedded emissions per tonne, direct and, where required, indirect, with the period they cover.
The monitoring methodology and the verifier, or the date verification is planned.
Any carbon price paid, with evidence.

Suppliers in India, Vietnam, Türkiye and South Africa are all being asked for the same file. Those that can produce it quickly are worth paying attention to. See how suppliers are preparing in green finance for Turkish steel and cement exporters and the CBAM cost guide for Indian steel exporters.

Run the numbers

The CBAM calculator works out the cost per tonne year by year to 2034 for each sector, origin and route, with or without actual emissions and carbon price paid. The sector cost tables show how the charge grows as EU free allocation ends.

This is general guidance, not legal advice. Check DEHSt's current guidance for your case.