Updated: November 9, 2026
Importing steel or aluminum products from China into the European Union now involves more than checking customs duties, shipping costs, and delivery schedules.
Since January 1, 2026, the EU's Carbon Border Adjustment Mechanism (CBAM) has entered its definitive implementation phase, introducing new obligations for importers of certain carbon-intensive goods.
For businesses sourcing steel, aluminum, and related industrial products from Chinese manufacturers, CBAM can affect compliance planning, supplier documentation, and the overall cost of importing.
However, not every steel or aluminum product is covered, and not every importer faces the same requirements.
This guide explains which shipments may fall under CBAM, what the 50-tonne threshold means, what information importers should request from Chinese suppliers, and how to prepare shipments without unnecessary customs complications.
1. What Is EU CBAM and Why Does It Matter in 2026?
The Carbon Border Adjustment Mechanism is an EU policy designed to address carbon leakage.
Carbon leakage occurs when production shifts to countries with less stringent carbon-related requirements, potentially undermining the EU's emissions reduction policies.
CBAM complements the EU Emissions Trading System (EU ETS) by introducing a carbon-related obligation for certain imported goods.
According to the European Commission's CBAM overview, the definitive regime began on January 1, 2026.
This represents a significant change from the transitional reporting phase, which ran from October 2023 through December 2025.
Under the definitive system, qualifying importers must address authorization, embedded emissions reporting, and CBAM certificate obligations.
For importers buying from China, the practical impact is clear:
A freight quotation and commercial invoice are no longer the only information needed to evaluate certain steel and aluminum imports.
Importers must also determine whether their products fall within CBAM and whether the required emissions information can be obtained.
2. Which Products Are Covered by CBAM?
CBAM currently covers selected goods in six sectors:
- Iron and steel
- Aluminum
- Cement
- Fertilizers
- Electricity
- Hydrogen
However, coverage is determined by the specific product classification listed in the applicable CBAM legislation, not simply by the general industry or material description.
For example, some steel and aluminum articles may fall within the covered product codes, while other downstream products may not.
The European Commission provides sector-specific CBAM information for importers and non-EU manufacturers.
Why CN Codes Matter
EU customs classification uses Combined Nomenclature (CN) codes.
Before importing a product, the buyer should verify its correct classification and compare it with the relevant CBAM product list.
A general description such as "steel parts" or "aluminum accessories" is not enough to establish whether CBAM applies.
For example, two products made from similar materials may have different customs classifications and different compliance requirements.
Importers should avoid assuming that every metal product is automatically covered.
Practical tip: Ask the supplier for a detailed product description, manufacturing information, and proposed HS classification, then verify the relevant EU CN code with a customs specialist.
3. The 50-Tonne Threshold: Does Your Shipment Qualify for an Exemption?
One of the most important changes to the CBAM framework is the introduction of a single mass-based threshold.
Under the simplified rules, importers whose relevant CBAM goods do not exceed the applicable annual threshold of 50 tonnes may qualify for an exemption.
However, several details require attention.
The Threshold Is Annual
The threshold generally concerns the relevant imports over a calendar year, not the weight of one individual shipment.
Importers cannot assume that splitting cargo into several smaller consignments automatically removes CBAM obligations.
The Threshold Applies to Relevant Goods
The calculation concerns goods within the applicable CBAM scope. It should not simply be based on the total weight of everything a company imports.
Electricity and Hydrogen Require Separate Attention
The general 50-tonne exemption does not extend to electricity and hydrogen in the same way.
The European Commission's CBAM compliance guidance explains the authorization requirements and threshold framework.
Example: A European Importer Buying Steel Products
Consider a hypothetical German company importing covered steel products from China.
If its relevant annual imports fall below the applicable threshold, it may qualify for the mass-based exemption.
If its annual imports exceed the threshold, the importer must assess the authorization, reporting, and financial obligations that apply.
The calculation should consider the company's relevant imports for the calendar year, rather than looking at individual containers in isolation.
Importers should monitor cumulative quantities throughout the year instead of checking CBAM exposure only when a shipment is booked.
4. What Must EU Importers Do Under the Definitive CBAM Regime?
For importers subject to CBAM obligations, compliance involves several connected activities.
Obtain the Required Authorization
Relevant importers or their indirect customs representatives must meet the authorization requirements for CBAM declarants.
The authorization process is managed through the designated CBAM systems and the relevant national competent authority.
Importers should confirm their status before arranging the release of covered goods for free circulation.
Collect Embedded Emissions Information
CBAM focuses on the emissions associated with producing the covered goods.
Importers need to determine the embedded emissions to be declared using an accepted methodology.
Depending on the applicable requirements, this may involve actual verified emissions data or permitted default values.
Submit Annual Declarations
The first annual CBAM declaration covers relevant imports made during 2026.
The initial deadline is September 30, 2027.
Meet Certificate Obligations
The certificate system connects the carbon-related obligation to the EU ETS framework, with the applicable methodology and adjustments governing the final number of certificates.
The first certificates corresponding to 2026 imports are due to be surrendered in 2027.
The European Commission's CBAM communication and guidance page explains the reporting and certificate arrangements.
Importers should budget for these obligations separately from normal customs duties and freight costs.
5. What Information Should Chinese Suppliers Prepare?
For many European importers, one of the most challenging aspects of CBAM is obtaining reliable information from manufacturers outside the EU.
A Chinese supplier may have extensive experience preparing commercial invoices, packing lists, and export declarations, but emissions-related information requires a different process.
Product and Manufacturing Information
Importers may need to obtain:
- Detailed descriptions of the goods.
- Product classifications.
- Manufacturing installation information.
- Production process details.
- Quantities and relevant production periods.
- Data needed to determine embedded emissions.
Embedded Emissions Data
Where actual emissions are reported, the manufacturer may need to calculate the relevant production emissions using the prescribed CBAM methodology.
Verification requirements must also be followed where applicable.
The European Commission has published technical guidance for non-EU installation operators, including specific documents for iron, steel, and aluminum.
These materials are available from the official CBAM legislation and guidance page.
Why Early Supplier Communication Matters
An importer should not wait until the shipment reaches the destination port before asking whether the manufacturer can provide emissions information.
Even if the immediate customs release process is properly arranged, missing or unreliable data can create later reporting and compliance problems.
For purchasing teams, CBAM-related documentation should become part of supplier onboarding and order planning.
6. How Does CBAM Affect Shipping from China?
CBAM does not replace the ordinary international freight process.
Importers still need to arrange transportation, prepare commercial documents, and comply with normal customs requirements.
However, CBAM creates additional compliance considerations that should be addressed before cargo departure.
Confirm Product Classification Before Booking
The buyer should verify whether the imported goods fall within the CBAM scope.
This is especially important for mixed shipments containing multiple types of steel or aluminum products.
Keep Product Descriptions Consistent
Commercial invoices, packing lists, customs declarations, and relevant compliance records should identify the goods accurately.
Different documents serve different purposes, but inconsistent product information can complicate customs and compliance reviews.
Coordinate with the Customs Representative
The importing company should confirm which party is responsible for the CBAM-related declaration and authorization requirements.
A freight forwarder may coordinate transportation and shipment documents, but CBAM compliance responsibilities should not automatically be transferred to the logistics provider.
Plan for Additional Compliance Costs
The total import budget may need to account for:
- International freight charges.
- Customs clearance services.
- Normal import duties and taxes, where applicable.
- CBAM-related financial obligations.
- Data collection and verification costs.
- Administrative compliance expenses.
These costs vary by product, importer, reporting method, and regulatory circumstances.
A low freight rate does not necessarily mean a low overall import cost.
7. CBAM vs. Customs Duties: What Is the Difference?
CBAM and ordinary import customs duties serve different purposes.
| Category | Ordinary Customs Duties | CBAM |
|---|---|---|
| Main basis | Customs classification, origin, value, and applicable tariff rules | Embedded emissions and relevant CBAM rules |
| Main objective | Apply customs tariff measures | Address carbon-related cost differences |
| Product coverage | Depends on the customs tariff | Selected CBAM goods |
| Financial treatment | Duties are generally assessed through the import process | CBAM certificate obligations follow the applicable annual system |
| Key preparation | Classification, origin, valuation, and customs documents | Classification, authorization, emissions data, and CBAM reporting |
A product may be subject to both ordinary customs duties and CBAM obligations.
Importers should therefore avoid treating CBAM as a replacement for existing customs tariffs.
The actual financial obligation depends on the relevant emissions calculations, applicable adjustments, and other CBAM requirements.
8. Common Mistakes Importers Should Avoid
Mistake 1: Assuming All Steel and Aluminum Products Are Covered
CBAM applies to specified product classifications.
Importers should verify the actual CN code rather than relying on a broad material description.
Mistake 2: Applying the 50-Tonne Threshold to Each Shipment
The threshold is generally assessed annually.
Breaking a shipment into smaller consignments does not automatically provide an exemption.
Mistake 3: Asking the Supplier for Emissions Data Too Late
Manufacturers may need time to collect production information and prepare emissions calculations.
Start discussions during sourcing and purchase negotiations.
Mistake 4: Confusing Customs Clearance with CBAM Compliance
Completing an import declaration does not, by itself, mean that all annual CBAM reporting and certificate obligations have been fulfilled.
Mistake 5: Ignoring the 2027 Deadline
The first annual declaration and corresponding certificate surrender obligations fall in 2027 for relevant 2026 imports.
Importers should establish recordkeeping and monitoring procedures during 2026, rather than waiting until the filing deadline approaches.
9. CBAM Import Checklist for Businesses Sourcing from China
Before arranging a steel or aluminum shipment, importers should confirm the following:
Product eligibility
- Is the product covered by CBAM?
- Has the EU CN classification been verified?
- Are any special exclusions relevant?
Importer obligations
- What is the total annual quantity of relevant CBAM goods?
- Does the 50-tonne threshold apply?
- Is CBAM declarant authorization required?
- Who will coordinate the compliance process?
Supplier information
- Can the manufacturer identify the relevant production installation?
- Can it provide the necessary emissions-related information?
- Are actual emissions data available?
- Will verification be necessary?
Shipping and documentation
- Are commercial product descriptions accurate?
- Are the invoice and packing list complete?
- Has the customs representative been informed of the relevant requirements?
- Are the planned import procedures consistent with the buyer's CBAM status?
Cost and recordkeeping
- Have potential CBAM-related costs been considered?
- Is the importer maintaining records of annual import quantities?
- Are the relevant declaration deadlines being monitored?
This checklist helps purchasing teams identify issues before cargo leaves China.
Frequently Asked Questions
1. Does EU CBAM apply to every steel or aluminum product imported from China?
No. CBAM applies to specified goods identified through the relevant EU CN classifications. Importers must verify whether their products fall within the applicable scope.
2. Is every importer required to purchase CBAM certificates?
No. The applicable requirements depend on the product, import quantities, available exemptions, and the importer's position under the CBAM framework. Qualifying importers subject to the definitive regime must comply with the relevant certificate obligations.
3. Does the Chinese manufacturer have to pay CBAM?
CBAM obligations generally fall on the relevant EU importer or authorized indirect customs representative. However, Chinese manufacturers may need to provide production and emissions information, and commercial contracts may allocate the economic cost between trading partners.
4. When is the first CBAM annual declaration due?
The first annual CBAM declaration, covering relevant goods imported in 2026, is due by September 30, 2027, together with the corresponding certificate surrender requirements.
Conclusion
EU CBAM introduces another important consideration for businesses importing steel, aluminum, and other covered products from China.
The key challenges are not limited to carbon-related costs. Importers must also verify product classification, understand authorization and threshold requirements, coordinate emissions data with suppliers, and prepare for annual reporting.
For international purchasing teams, early preparation is more effective than addressing compliance questions after goods have already shipped.
A clear understanding of CBAM responsibilities can help businesses avoid unnecessary documentation problems and make better-informed import decisions.
Planning to Import Industrial Products from China?
International shipments involve more than freight rates. Accurate cargo information, customs documentation, and clear delivery arrangements all contribute to a more reliable supply chain.
Deeplinker helps businesses evaluate international freight options and coordinate shipment requirements based on their cargo, destination, and delivery needs.
Contact Deeplinker to discuss your shipment
References
- European Commission — Carbon Border Adjustment Mechanism
- European Commission — CBAM Definitive Regime
- European Commission — CBAM Sectors
- European Commission — CBAM Legislation and Guidance
- European Commission — CBAM Communication and News
Disclaimer: This article provides general information as of November 9, 2026. CBAM obligations depend on the applicable legislation, product classification, importer status, and transaction details. Importers should consult relevant EU authorities or qualified customs and compliance professionals.
