Importing small volumes from China to the EU in 2026: do I pay the carbon border tax (CBAM)?
Answer
For most small goods, no. The EU Carbon Border Adjustment Mechanism (CBAM) definitive regime applies from 2026-01-01 and covers only certain carbon-intensive goods (iron and steel, aluminium, cement, fertilisers, electricity, hydrogen; Annex I decides). Clothing, toys and homeware are not covered. Even for those goods, only importers bringing in more than 50 tonnes must apply to become an authorised CBAM declarant and buy CBAM certificates.
- Applies to
- Chinese sellers and EU importers bringing goods into the EU.
Key rules
| Item | Detail | Source |
|---|---|---|
| Definitive regime starts | 2026-01-01 | European Commission: CBAM definitive regime |
| Threshold | Importers of more than 50 tonnes of CBAM goods (single mass-based threshold) must apply for authorised CBAM declarant status | Same |
| Certificates | Authorised declarants buy CBAM certificates from the competent authority in their EU country | Same |
| Goods | Iron and steel, aluminium, cement, fertilisers, electricity, hydrogen (Annex I codes decide) | Annex I; amending Regulation (EU) 2025/2083 |
What you can do yourself
- Check whether your commodity code is in CBAM Annex I. Everyday consumer goods usually are not.
- If you sell steel or aluminium products (screws, aluminium profiles), estimate your EU buyer's total CBAM imports per year; above 50 tonnes they will need emissions data.
- If an EU buyer asks you for "emissions data", they are working on CBAM; ask what format they need.
When to use a licensed professional
- If your goods sit on the edge of Annex I, talk to an EU customs or CBAM compliance adviser.
- If you need to supply factory emissions data, use an accredited verifier.
Check before you pay, and warning signs
- "All exports to the EU pay carbon tax" is wrong.
- Selling you carbon verification without looking at your commodity codes is a warning sign.
Unknowns
- Whether the 50 tonnes is counted per importer per year, whether exceeding it applies to the whole year, and whether electricity and hydrogen are excluded: seen only in summaries, not checked in the Regulation text.
- The full Annex I code list: not read this time; requested.
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