Positions · EU dossier

CBAM – Carbon Border Adjustment Mechanism

The EU Carbon Border Adjustment Mechanism covers, among others, imports of aluminium and iron and steel products. On this page: procedure stage, upcoming dates, acts from the Law register and the full state of play.

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Reviewed 21.10.2026 · next review by 20.11.2026

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At a glance

Definitive period since 01.01.2026; first declaration for 2026 due by 30.09.2027; extension COM(2025) 989 – EP–Council negotiations.

01.02.2027start of sales of CBAM certificatesReg. (EU) 2025/2083
30.09.2027deadline for the first CBAM declaration and surrender of certificates for 2026Reg. (EU) 2025/2083
EUR 82.32certificate price (1 t CO₂) for Q3 2026; Q1 EUR 75.36, Q2 EUR 75.28European Commission, DG TAXUD
CN 7601, 7603–7614, 7616aluminium covered by CBAM; copper, zinc and lead outside the scopeReg. (EU) 2023/956, Annex I

Procedure stage and dates

2023/956Application · since 01.01.2026
2025/0419(COD)Trilogues · since 15.09.2026
2026/0212(COD)Parliament and Council · since 17.09.2026

Stages: 1. Announced2. Consultation3. Proposal4. Parliament and Council5. Trilogues6. Adoption and publication7. Application8. Review

Upcoming dates

14.12.2026indicative date of the plenary vote (OEIL forecast)EU ETS review – proposal COM(2026) 616
04.01.2027publication of the certificate price for Q4 2026 (Q1–Q3: EUR 75.36 / 75.28 / 82.32)CBAM (Regulation 2023/956 as amended by Regulation 2025/2083)
01.02.2027start of sales of CBAM certificatesCBAM (Regulation 2023/956 as amended by Regulation 2025/2083)
31.03.2027verified emissions report for 2026EU ETS Directive (2003/87/EC)
30.09.2027first CBAM declaration and surrender of certificates for 2026CBAM (Regulation 2023/956 as amended by Regulation 2025/2083)
30.09.2027first CBAM declaration and surrender of certificates for 2026 (Regulation 2023/956)CBAM implementing provisions (Act of 21.11.2025)
01.01.2028proposed extension to downstream products (COM(2025) 989)CBAM (Regulation 2023/956 as amended by Regulation 2025/2083)
01.01.2028CBAM factor 90%EU ETS Directive (2003/87/EC)

Chamber position

No documents have been published on this dossier.

Dossier documents and sources in the Library →

Acts in the Law register

EU policy

Carbon Border Adjustment Mechanism – state of play

The Carbon Border Adjustment Mechanism (CBAM) has been in its definitive period since 1 January 2026. Aluminium is the only non-ferrous metal covered. Obligations, deadlines, the extension to downstream goods and implementation in Poland – based solely on official documents.

Definitive period since 01.01.2026Extension in procedureRegulation (EU) 2023/956 · Art. 192(1) TFEU

The mechanism applies – first settlement for 2026 by 30.09.2027

An importer of CBAM goods – cement, iron and steel, aluminium, fertilisers, electricity and hydrogen – needs the status of authorised CBAM declarant if it imports more than 50 t a year (electricity and hydrogen – no threshold). Certificates will be sold from 1 February 2027, and the declaration for 2026 and the surrender of certificates are due by 30 September 2027. Proposal COM(2025) 989 extending CBAM to downstream goods is under negotiation between the European Parliament and the Council.

Certificate price, Q3 2026

EUR 82.32

per tonne CO₂e; Q1 EUR 75.36, Q2 EUR 75.28 – average EU ETS auction price

As of 21.10.2026

Procedure: Regulation, simplification and extension

Diagram 1. Procedure: Regulation 2023/956, simplification 2025/2083 and extension COM(2025) 989

Work is also under way on the Temporary Decarbonisation Fund COM(2025) 990 (Parliament position 15.09.2026) and on the EU ETS review COM(2026) 616 of 17.07.2026, which proposes to reintroduce from 2028 15% of the free allocation phased out in CBAM sectors and to spread the phase-out until the end of 2037.

Importer obligations and the rising charge

Diagram 2. Importer’s annual cycle and share of emissions subject to the CBAM charge 2026–2034

Share derived from the CBAM factor, i.e. the part of free allocation kept in the EU ETS: 97.5% in 2026, 95% in 2027, 90%, 77.5%, 51.5%, 39%, 26.5% and 14% in 2033; none from 2034 (Art. 10a(1a) of Directive 2003/87/EC). Certificate price: quarterly average in 2026, weekly average of allowance auction prices from 2027 (Art. 21). The ETS review COM(2026) 616 proposes to change this schedule.

Timeline

Diagram 3. Timeline 2023–2028

Importers who applied for the status by 31.03.2026 could import provisionally until the decision (Art. 17(7a)). The dates 01.02.2027 and 30.09.2027 follow from Regulation 2025/2083; 01.01.2028 is from proposal COM(2025) 989 and may change. The “today” line moves automatically.

Relevance for non-ferrous metals

Aluminium within CBAM

Covered: CN 7601 (unwrought aluminium), 7603–7614 and 7616; gases: CO₂ and perfluorocarbons. Scrap 7602 and household articles 7615 remain outside. Default values for aluminium carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028 (Impl. Reg. 2025/2621). In the first days of 2026 aluminium accounted for 0.3% of the mass of CBAM goods declared in the EU.

Copper, zinc, lead

They are not covered by CBAM. In review report COM(2025) 783 of 16.12.2025 the Commission states that its analysis does not currently identify the non-ferrous metals sector – lead, zinc and copper – as a candidate for inclusion, owing to the sector’s complexity. The next review step (2027) is to address indirect emissions and other sectors, such as chemicals.

Aluminium scrap

Proposal COM(2025) 989 brings pre-consumer aluminium scrap (ex 7602) and steel scrap in as precursors; post-consumer scrap stays outside, as covering it could discourage the circular economy. Parliament (15.09.2026) proposes covering all scrap 7602 as a precursor, with evidence for post-consumer scrap and declaration of its quantity. The Council largely agrees with including pre-consumer scrap.

Downstream goods

The Commission proposes covering, from 01.01.2028, 180 products with high steel and aluminium content (94% industrial goods, on average 79% steel and aluminium). The list also includes copper winding wire and conductors (ex 8544) – insofar as they contain steel or aluminium. Parliament widens the list and proposes a 5 t threshold for aluminium products; the Council foresees an annual review of the list.

Free allocation and exports

EU aluminium producers lose free allocation under the EU ETS at the pace of the CBAM factor (diagram 2). The Temporary Decarbonisation Fund COM(2025) 990 – financed from 25% of certificate revenue for 2026–2027 – is to support export production in 2028–2029, including 7 aluminium CN codes. The ETS review COM(2026) 616 proposes to reintroduce 15% of the phased-out allocation from 2028.

Implementation in Poland

The Act of 21.11.2025 amending the act on the system for managing greenhouse gas emissions and other substances (Dz.U. 2025 poz. 1863) has applied since 13.01.2026. The authorised CBAM declarant status is granted by the Director of the Tax Administration Chamber in Poznań (Dz.U. 2026 poz. 11), access to the CBAM registry is via PUESC, and KOBiZE handles, among other things, corrections of transitional reports.

Next steps

EP–Council negotiations

The Council adopted its general approach on COM(2025) 989 on 12.06.2026 and aims for agreement before the end of the year; Parliament adopted its position on 15.09.2026 and referred both proposals (989 and 990) for negotiations. No agreement has been announced yet. EP rapporteurs: Mohammed Chahim (extension) and Pascal Canfin (fund).

The year 2027

From 01.02.2027 certificates are sold on the common platform; from 2027 the price is set weekly and the quarterly holding must be at least 50%. The first declaration and surrender of certificates for 2026 are due by 30.09.2027; repurchase by 31.10, cancellation of unused certificates on 01.11.2027. Default values and mark-ups are to be revised in 2027 at the latest.

Reviews

Each year by 30.04 the Commission checks that the 50 t threshold exempts no more than 1% of emissions – for 01.04.2025–31.03.2026 it was 0.87%, so the threshold stays. The next report on CBAM application is due before 01.01.2028 and every two years thereafter (Art. 30). Feedback on the ETS review COM(2026) 616 can be submitted until 03.11.2026.

Poland’s position

On 12.05.2026 the Sejm’s EU Affairs Committee (sitting no. 138) endorsed the government position on COM(2025) 989: support for the extension and anti-circumvention measures, with a transition period, and opposition to the broad empowerment in Art. 27a. The government position on the fund COM(2025) 990 is negative (sitting no. 146, 10.06.2026).

Key facts

Act: Regulation (EU) 2023/956 of the European Parliament and of the Council of 10.05.2023 establishing a carbon border adjustment mechanism
Publication: OJ L 130 of 16.05.2023, p. 52; applies from 01.10.2023, definitive period from 01.01.2026
Amendment: Regulation (EU) 2025/2083 of 08.10.2025, OJ L 2025/2083 of 17.10.2025
Scope: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen (Annex I)
In progress: COM(2025) 989 – 2025/0419(COD); COM(2025) 990 – 2025/0418(COD)
As of: 21.10.2026

Sources

Information note based on official documents of the EU, the Polish Sejm and the Polish Journal of Laws; not a legal interpretation. The binding texts are those published in the Official Journal of the EU; proposals COM(2025) 989 and 990 may change during the procedure.

Change log

24.10.2026Dossier page: procedure stage, upcoming dates and acts from the Law register.
21.10.2026State-of-play analysis: certificate prices for Q1–Q3 2026, proposal COM(2025) 989 after the EP vote of 15.09.2026, ETS review COM(2026) 616.

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