Paying CBAM on default values? You’re probably overpaying.

Below 50 t per calendar year (all CBAM goods together, net mass) you need no authorisation, no declaration and no certificates. The count is per importer: it includes all your customs brokers and also returned goods. Once you go over 50 t, all CBAM obligations apply for that year, and customs will not release CBAM goods to an importer who is not authorised (except applicants covered by the Y238 transitional rule). If you are close to the limit, apply early. Hydrogen and electricity have no threshold.

Y238 is the TARIC code for importers who applied for authorised declarant status by 31.03.2026 and are still waiting for a decision. They can keep importing with Y238 until 31.12.2026 (extension decided by the European Commission, announced in Romania by the Ministry of Finance on 16.09.2026). If you applied later, you cannot import more than 50 t of CBAM goods per year until you are authorised – so a complete, correct file matters.

In Romania, companies that were not established during the two financial years before the application must provide a financial guarantee (Order MF 1188/2026, published on 10.09.2026): a bank guarantee letter, in euro. According to the Ministry, the amount is based on the maximum number of certificates estimated for the year of application and the following year. We help you estimate that number realistically. Other Member States have their own rules.

Start early, write in their language and ask for exactly what the EU template needs – not a generic “carbon footprint”. If you buy through a trader, ask for the name and address of the factory. We follow up on day 3, 7 and 10 and escalate. If there is still no usable data, that line is declared on default values – allowed, just more expensive – and you keep a file of every attempt to show the authority.

Open the free calculator and choose your CN code, country and tonnes. It shows default values (with the 10/20/30% mark-up), the free allocation adjustment and the cost for every year until 2034, with the formula and the official sources. Example: 40 t of aluminium profiles from Türkiye cost €8,757 on default values in 2026 and €1,158 with hypothetical verified data from a secondary producer.

An independent body accredited under the EU CBAM rules that checks the factory’s emissions report. Only verified actual emissions can replace default values. The first verification requires a physical visit to the installation. It is the producer (operator) who decides to monitor its emissions and commissions the verifier, so normally the factory pays – often reflected in its price. Market estimates range from about €5,000 to €50,000 per installation. Few verifiers were accredited by autumn 2026, so book early.

Certificates are sold from 1 February 2027 on the common central platform, open only to authorised declarants through the CBAM Registry. Certificates for 2026 imports are bought between February and 30.09.2027 at the 2026 quarterly prices (Q1 €75.36, Q2 €75.28, Q3 €82.32; Q4 published on 04.01.2027). In 2027 you also have to buy, every quarter, certificates for at least 50% of the emissions imported since the start of 2027. So 2027 is the year you pay twice – plan the cash now.

Commercially, many distributors do – some large ones show a separate CBAM surcharge per item, calculated with the official formula. Whether you can do it depends on your contracts and Incoterms; check with your lawyer. We calculate the surcharge per item and per tonne from your actual import data (Annual Plus).

Usually not. The broker fills in the CBAM codes on the customs declaration (Y128, Y238 or Y137) based on what you tell them. Supplier data, verification, the declaration and the certificates remain your responsibility as importer – unless an indirect customs representative explicitly takes on the declarant role.

From 2028 the mark-up on default values reaches 30%. The EU is also discussing an extension of CBAM to around 180–200 downstream steel and aluminium products (Commission proposal COM(2025) 989; Council position of 12.06.2026). It is not final yet. We follow it and tell you if your CN codes are affected.