The definitive CBAM regime started on 1 January 2026: embedded emissions in steel and aluminium now carry a real cost. What importers must prepare - and what the 2028 expansion could mean for vehicle parts.
The Carbon Border Adjustment Mechanism left its transition phase on 1 January 2026. After three years of quarterly reporting with no financial consequence, imported iron, steel and aluminium now carry a real, billable carbon cost at the EU border. For anyone importing European-car parts - castings, forgings, machined components, body panels - this is no longer a compliance footnote. It is a landed-cost line.
Three duties now apply. First, authorisation: importers of covered goods must hold authorised CBAM declarant status - the deadline to apply was 31 March 2026 for goods imported since January. Second, the annual declaration: embedded emissions in covered imports must be reported and, from February 2027, settled with CBAM certificates - priced weekly off the EU ETS, which has been trading around EUR 75-80 per tonne. The liability accrues in-year, so the cash cost of 2026 imports lands well before the certificates are surrendered.
The 2025 Omnibus simplification replaced the old EUR 150-per-consignment exemption with an annual mass threshold of 50 tonnes per importer. Small occasional imports below that line are exempt from authorisation and declaration; anything regular - which describes every professional parts programme - sits above it. Check your tonnage on the covered CN codes before assuming you are too small to keep the file.
Today CBAM covers iron, steel, aluminium, cement, fertilisers, hydrogen and electricity. Finished vehicle parts are largely outside the scope - for now. The European Commission has signalled a downstream expansion from 2028 covering roughly 180 additional steel- and aluminium-intensive products, with vehicle parts on the proposed list. Suppliers who assume finished parts stay exempt are planning against a deadline that has a date on it.
For every programme we ship we keep mill-level material documentation available, track which references fall on covered CN codes, and quote with the documentation pack a customs broker needs to calculate embedded emissions. When the 2028 expansion lands, the difference between a week of paperwork and a blocked container is the paperwork you already have. Send us your part list - we will flag which lines sit on covered codes today and what to prepare for the ones coming next.