CBAM 2026: The Operational Guide for Italian Importers

January 1, 2026 marked CBAM's transition from the transitional to the definitive phase. From that date, importing steel, aluminium, cement, fertilisers, hydrogen or electricity into Italy from non-EU countries is no longer a simple customs operation: it entails annual reporting obligations, the purchase of certificates linked to the European carbon price, and the possibility of penalties up to €100 for every tonne of CO₂ not covered.

The regulatory framework has changed substantially in recent months. Regulation (EU) 2025/2083 of 8 October 2025, published in the EU Official Journal on 17 October 2025, rewrote several rules of the definitive phase: it introduced an exemption threshold of 50 tonnes per year, postponed the first declaration to 30 September 2027, deferred certificate sales to February 2027, and reduced the quarterly threshold from 80% to 50%. On 7 April 2026 the European Commission published the first quarterly certificate price: €75.36 per tonne of CO₂ for the first quarter.

This guide is designed for those importing CBAM goods into Italy who need a complete operational roadmap: what has changed, who must do what, by when, whom to contact, and how much it will cost. The rules are the same throughout the EU, but Italian operational procedures (competent authorities, customs codes, integration with the AIDA system) have specificities that often do not emerge from European documents.

CBAM: what it is and why it exists

The Carbon Border Adjustment Mechanism is the instrument through which the European Union applies a carbon cost on imports of high-emission-intensity goods from countries that do not have a CO₂ pricing system equivalent to the EU ETS. It was established by Regulation (EU) 2023/956 of 10 May 2023 and is one of the pillars of the Fit for 55 package and the European Green Deal.

The rationale: addressing carbon leakage

The problem that CBAM addresses is so-called carbon leakage: the risk that European companies subject to ETS costs relocate production to countries with less stringent environmental rules, or are simply replaced on the European market by cheaper imported products manufactured without emission constraints. In both cases, the net effect on the climate would be zero or negative, because emissions would shift rather than decrease.

CBAM neutralises this asymmetry. Anyone importing goods subject to the mechanism must purchase certificates whose price is linked to that of EU ETS allowances. The carbon cost borne by European producers and that applied to imported goods should thus tend to converge.

EU ETS and CBAM: two connected mechanisms

The link between ETS and CBAM is structural. The CBAM certificate price is not decided by the Commission: it is the average of EU ETS auction prices on the primary market. If the European carbon price rises, CBAM certificates rise. If it falls, they fall. There is no secondary market: CBAM certificates can only be purchased on the central EU platform, have annual validity, and are not transferable between operators.

The system starts progressively. In the same years that CBAM ramps up, the free ETS allowances allocated to CBAM-covered sectors are reduced symmetrically, reaching zero in 2034. This is the phase-in / phase-out principle: CBAM exactly compensates for the competitive disadvantage that the reduction of free allowances would create for European producers. The ETS phase-out runs until 31 December 2033 (with full elimination from 1 January 2034).

The three phases of CBAM

The transitional phase ran from 1 October 2023 to 31 December 2025: it involved only quarterly reporting obligations and no payment. The last report (Q4 2025) was due by 31 January 2026.

The definitive phase began on 1 January 2026. From that date the actual obligations are operational: authorised declarant status, specific customs declaration, calculation of embedded emissions, and purchase and surrender of certificates.

The 2028 extension is currently a legislative proposal presented by the Commission on 17 December 2025: it extends CBAM to approximately 180 downstream steel and aluminium products (mechanical components, processed goods, finished products) from 1 January 2028. It should be followed closely: those currently outside the scope because they import processed goods rather than raw materials may be brought back in by 2028.

Sectors and products covered from 2026

The sectors covered by CBAM in the definitive phase are six, listed in Annex I of Regulation 2023/956:

• Cement, including clinker and composite cements
• Iron and steel, from crude to rolled products
• Aluminium, unwrought and specific semi-finished products
• Fertilisers, nitrogen-based (urea, ammonium nitrate and others)
• Electricity
• Hydrogen

Alongside finished products, CBAM covers certain industrial precursors: clinker for cement, nitric acid and ammonia for fertilisers, ferro-silicon for steel, and unwrought aluminium for semi-finished products.

The precise identification of goods subject to the mechanism is based on Combined Nomenclature (CN) codes: every imported product has a customs CN code, and CBAM applies only if that code falls within the Annex I list. This is the first check the importer must make. A technical but crucial detail: CBAM applies to products listed in Annex I, even if incorporated in goods assembled elsewhere, when imported as such. A steel bolt imported loose is within CBAM; the same bolt imported already fitted in complex machinery is currently not (but could be from 2028, if the downstream extension passes).

For the more complex sectors (cement and fertilisers) CBAM considers both direct process emissions and indirect emissions linked to electricity consumed. For steel, aluminium and hydrogen, only direct emissions currently apply. This is a detail that significantly affects the final calculation and costs.

Each sector deserves a dedicated deep-dive: see our guides on CBAM steel for Italian importers, CBAM cement and clinker and CBAM aluminium: declaration and calculation.

The 50-tonne threshold: who is exempt

One of the most significant changes in Regulation 2025/2083 is the introduction, under Article 2a, of a mass-based exemption threshold: importers who cumulatively import less than 50 tonnes of CBAM goods in a calendar year are exempt from all obligations. The threshold has several important characteristics.

It is cumulative on an annual basis, not per individual import. What counts is the total net mass of CBAM products imported in the calendar year, regardless of the number of customs operations. If in the first months one is below threshold but by mid-year exceeds 50 tonnes, the entire year falls under the CBAM regime, including imports already made.

It does not apply to hydrogen and electricity. For these two sectors there is no exemption threshold: the obligation applies from any quantity.

It must be declared at customs even if respected. From 1 January 2026, every customs declaration for CBAM goods must state the reason why the import is permitted: authorised declarant status, de minimis exemption, or other grounds. To declare the exemption, customs code Y137 is used.

It is not fixed forever. By 30 April each year, the Commission may modify it by delegated act to ensure that at least 99% of embedded emissions imported into the EU remain covered by CBAM. The 2026 threshold is 50 tonnes; the 2027 threshold will be known by end of April 2027.

For many Italian SMEs, this threshold is the difference between being inside or outside CBAM. A careful mapping of import flows is worthwhile, because some product codes have high unit densities (steel in particular) and 50 tonnes is reached sooner than expected.

Authorised CBAM declarant status

To import CBAM goods in quantities exceeding the 50-tonne threshold, it is necessary to have obtained authorised CBAM declarant (ACD) status from the national competent authority. This is the main operational prerequisite of the definitive phase.

Competent authorities in Italy

The Italian system is composed of two parts:

• Ministry of the Environment and Energy Security (MASE): the competent authority for granting authorisations. It receives applications, assesses requirements, and grants or denies status.
• Customs and Monopolies Agency (ADM): manages the operational customs side. It verifies at the border that imports are compliant (authorisation present or exemption correctly declared). ADM published its notice of 22 October 2025 and Circular 36/2025 of 24 December 2025 with operational instructions for the definitive phase.

The two bodies communicate through the integration between the European Commission's CBAM Registry and the Italian customs system AIDA.

Application procedure and timelines

The procedure for applying for authorised declarant status is governed by Implementing Regulation (EU) 2025/486 applicable from 28 March 2025, which defined the operational detail: required data, application format, evaluation criteria, and processing timelines.

In Italy, the application is submitted to MASE via the European CBAM Registry channel (cbam.ec.europa.eu). Identification requires SPID, CIE or CNS digital credentials and is conditional on meeting certain requirements: valid EORI code, registered office or permanent establishment in an EU Member State, absence of serious customs and tax infringements, adequate financial capacity, and operational capability to manage CBAM obligations.

MASE has 120 days to process the application. The decision (grant or refusal) is notified via certified email. Once authorised, importers are registered in the European CBAM Registry and can operate normally.

The transitional derogation of 31 March 2026

To avoid the risk of an operational blockage at the start of the definitive phase, with a concentrated influx of applications, Article 17 of Regulation 2025/2083 introduced a transitional derogation: importers who submitted their authorisation application by 31 March 2026 may continue to import CBAM goods even before MASE has decided, but no later than 30 September 2026. Imports made during this period remain valid; declaration and certificate surrender obligations will apply once authorisation is granted.

Those who missed the 31 March 2026 deadline and exceed the 50-tonne threshold find themselves in a complicated situation: in case of authorisation refusal, the competent authority will retroactively determine the embedded emissions of goods imported between 1 January 2026 and the decision date, applying the relevant penalties.

The advice for those still in doubt: submitting the application to MASE before exceeding the threshold, even if uncertain of exceeding it, is the prudent path that ensures operational continuity.

For a step-by-step procedural guide, see Authorised CBAM declarant: how to obtain status from MASE.

How embedded emissions are calculated

The calculation of embedded emissions is the core component of CBAM and probably the most complex part of compliance. Regulation 2023/956, Annex IV and Implementing Regulation 2023/1773 define the methodology. Delegated acts published by the Commission on 17 December 2025 updated the default values applicable from 2026.

Direct vs indirect: the two components

Embedded emissions are divided into two categories:

• Direct emissions (Scope 1 under the GHG Protocol): those generated by the production processes of the non-EU installation that manufactured the good. For example, CO₂ released from the blast furnace in steel production.
• Indirect emissions (Scope 2, electricity-related): those generated by the production of electricity used in the processes.

For steel, aluminium and hydrogen, only direct emissions currently apply. For cement and fertilisers, both apply. The difference weighs heavily on the final certificate cost.

Two calculation methods: actual values vs default values

Regulation 2025/2083 confirmed a dual approach, expanding the possibility of using default values.

Actual values. The importer collects primary emission data directly from the non-EU producer: specific process measurements, installation-specific emission factors, actual energy consumption. The data must be supported by documentation and, to be used in the annual declaration, verified by an accredited third-party body.

Default values. When primary data is unavailable or unverifiable, the importer may use default values published by the Commission, specific to the country of origin and CN code. The 2026 values are based on the ten most emitting countries for each product and are subject to a mark-up to discourage using the default as a shortcut: +10% in 2026, +20% in 2027, +30% from 2028 onwards. Hydrogen and electricity have no mark-up.

When to use defaults and when to use actuals

The choice is not trivial and depends on three factors: the actual emission level of the supplier (if they are virtuous, actuals pay off); the cost of an accredited verification (indicative estimate generally between €5,000 and €15,000 for a first audit, lower in subsequent years); and the willingness of the non-EU supplier to provide structured and verifiable data.

In practice: if importing large volumes from virtuous and collaborative suppliers, investing in actual values pays off from the first year and repays the verification cost through reduced certificates. For small volumes or uncooperative suppliers, defaults are the quickest route, accepting the mark-up as a cost of the mechanism.

The dedicated deep-dive is in Accredited verification vs CBAM default values: when each option pays off.

CBAM certificate price in 2026

One of the year's most significant developments is the publication of the first quarterly CBAM certificate price. On 7 April 2026 the European Commission published the Q1 2026 price, set at €75.36 per tonne of CO₂.

How the price is calculated

The price is not decided by the Commission but mathematically derived. For 2026 it is calculated as the average of EU ETS auction clearing prices for the reference quarter, on the primary market. The methodology ensures coherence with the European carbon market: whoever imports CBAM goods pays for embedded CO₂ the same price that European producers pay through ETS.

For 2026 the calculation is quarterly: each quarter the Commission calculates and publishes the price applicable to that quarter's imports. From 2027 onwards it will shift to a weekly price, calculated as the average of ETS auctions from the previous week.

Publication calendar 2026

The Commission announced on 6 March 2026 the calendar for the year: each quarter's price is calculated during the first calendar week of the following quarter and published on the first working day of the week after the calculation.

The Q1 price (January-March) was published on 7 April; Q2, Q3 and Q4 prices are expected at the beginning of July, October 2026 and January 2027 respectively.

Certificate sales: from 1 February 2027

Although 2026 prices are already public, the actual purchase of certificates is postponed to 1 February 2027 (Article 20 of the Regulation, as amended by 2025/2083). From that date purchases can be made on the central EU platform managed by the Commission: no national platform is planned, and CBAM certificates are not transferable between operators (no secondary market).

The early publication of prices gives companies a planning tool. It allows importers to build a realistic estimate of the CBAM cost on the year's imports, integrate that cost into selling prices or contracts with end customers, and set up a possible staggered certificate purchase strategy in 2027 (which can be spread throughout the year to average out price risk).

The quarterly threshold at 50%

A novelty in Regulation 2025/2083 is the reduction of the minimum certificate holding threshold at quarter-end: from 80% (original rule) to 50% of estimated embedded emissions. This means that during 2027, in preparation for the annual declaration, importers must hold in their CBAM Registry account at least 50% of the certificates they expect to surrender, rather than 80%. This is a significant financial simplification, as it reduces the upfront capital commitment.

Annual declaration, surrender and penalties

The definitive phase of CBAM closes each year with the annual declaration and certificate surrender.

Contents of the annual declaration

The authorised declarant must submit, through the CBAM Registry, the following elements:

• the total quantity, by CN code, of CBAM goods imported in the previous year
• total embedded emissions (direct and indirect where applicable), expressed in tonnes of CO₂ equivalent
• identification data of the non-EU installations that produced the goods
• any carbon price already paid in the third country (with corresponding mark-down of certificates to surrender)
• accredited verification documentation, if actual values were used

Simultaneously with the declaration, the declarant surrenders a number of CBAM certificates equal to the tonnes of CO₂ declared, net of recognised compensations.

The deadline: 30 September 2027

Article 22 of the Regulation postponed the first declaration deadline: the declaration relating to 2026 imports must be submitted by 30 September 2027 (previously the deadline was 31 May). The deferral gives companies four additional months to consolidate data, complete accredited verifications, and purchase certificates.

For subsequent years, unless modified, the deadline remains 30 September of the year following the import year.

Penalties

The penalty system is structured on three levels.

Main penalty: those who fail to surrender required certificates are subject to a penalty of €100 for every tonne of CO₂ uncovered. The penalty is aligned with that in the EU ETS system for excess emissions. The amount is due in addition to, not instead of, the obligation to surrender the missing certificates.

Penalties for inaccurate or incomplete declarations: Member States must provide proportionate penalties for omissions or inaccuracies, aligned with the ETS penalty per incorrectly declared tonne. Serious and repeated cases may lead to revocation of authorised declarant status: in that case, the importer can no longer operate until a new authorisation is obtained (with timelines and procedure to restart).

Anti-fraud penalty on the 50-tonne exemption: Regulation 2025/2083 introduced a specific control mechanism for those declaring de minimis exemption while having exceeded the threshold. Penalties range from €300 to €500 per tonne declared exempt beyond the limit, accompanied by an anti-fraud system allowing the Commission to identify "non-genuine" commercial arrangements used to artificially split imports below threshold. The competent authority (in Italy, MASE) may request documentation to ascertain threshold exceedance and, upon confirmation, obliges the operator to register as an authorised declarant with retroactive effect.

Effective enforcement in Italy falls to ADM, which has the power to conduct targeted inspections spanning multiple years.

CBAM at customs: codes Y128, Y137 and operational procedures

From a customs perspective, from 1 January 2026 every import declaration for CBAM goods must state the reason justifying the operation. ADM has defined two dedicated codes to be entered in the SAD (Single Administrative Document) or the equivalent electronic customs declaration.

Y128: the importer holds authorised CBAM declarant status. It is paired with the CBAM account number issued by MASE and registered in the European CBAM Registry.

Y137: the import falls within the de minimis exemption (below the 50-tonne annual cumulative threshold). It must be declared at customs even though the exemption is obviously verifiable ex post.

The AIDA-CBAM Registry integration is automatic: the Italian customs system verifies data consistency at the time of clearance. A customs declaration lacking the correct CBAM code, or with data inconsistent with the European Registry, blocks clearance. Without authorisation and without correct indication in the SAD, goods remain at customs.

For operators who regularly work with indirect customs representatives, it is worth verifying that the freight forwarder has updated their systems with the new codes. Responsibility for the correct declaration lies with the importer (or the indirect customs representative, if holding the status).

The operational deep-dive is in CBAM at customs: codes Y128, Y137 and procedures.

Operational calendar 2026-2028

The CBAM timeline is dense. Here are the key deadlines:

1 January 2026 — Start of CBAM definitive phase (Reg. 2023/956 art. 36)

31 January 2026 — Last transitional phase report Q4 2025 (Reg. 2023/1773)

31 March 2026 — Deadline for MASE application under transitional derogation (Reg. 2025/2083 art. 17)

7 April 2026 — Publication of Q1 2026 certificate price: €75.36/tCO₂ (Commission Communication 6 Mar 2026)

30 April 2026 — Possible revision of 50-tonne threshold for 2027 (Reg. 2025/2083 art. 2a)

Early July 2026 — Publication of Q2 2026 certificate price (Commission Calendar)

Early October 2026 — Publication of Q3 2026 certificate price (Commission Calendar)

Early January 2027 — Publication of Q4 2026 certificate price (Commission Calendar)

1 February 2027 — Start of CBAM certificate sales on EU platform (Reg. 2025/2083 art. 20)

From 2027 — Weekly certificate pricing (Reg. 2025/2083)

30 September 2027 — First annual declaration for 2026 imports + certificate surrender (Reg. 2025/2083 art. 22)

1 January 2028 — Possible downstream extension (Commission proposal 17 Dec 2025)

2034 — Full phase-out of free ETS allowances for CBAM sectors (Reg. 2023/956)

Frequently asked questions

How is the CBAM declaration submitted?

From 2026, the declaration is submitted exclusively online through the European Commission's CBAM Registry (cbam.ec.europa.eu). Access requires digital credentials (SPID, CIE, CNS in Italy) and a valid EORI code. Only authorised declarants may submit the annual declaration. The platform guides compilation field by field: declarant general data, imports by CN code, embedded emissions, any carbon price paid in the country of origin, and verification attachments.

Who must submit the CBAM report?

In the definitive phase (from 1 January 2026), the obligated party is the authorised CBAM declarant: generally the importer established in the EU or, alternatively, the indirect customs representative if holding the status. Importers below the cumulative 50-tonne annual threshold are excluded (except for hydrogen and electricity). The transitional phase with quarterly reports ended on 31 December 2025: the last report (Q4 2025) was due by 31 January 2026.

How is the CBAM declaration compiled?

Compilation requires three types of structured data: customs data (quantities, CN codes, value, country of origin, taken from import accounting); emissions data (tonnes of CO₂ embedded per batch, calculated using verified actual values or Commission default values); verification data (accredited verifier report, if actual data). The system performs automatic consistency checks. Compilation requires at least 60-120 hours of internal work for the first year, depending on the number of CN codes and suppliers involved.

How to obtain authorised CBAM declarant status?

In Italy, the application must be submitted to MASE via the European CBAM Registry channel (cbam.ec.europa.eu). Requirements include: valid EORI code, digital identification (SPID/CIE/CNS), proof of registered office or permanent establishment in the EU, declarations of customs and tax compliance, and description of import activity and expected flows. MASE has 120 days to process the application. The transitional derogation of 31 March 2026 allowed those who applied by that date to operate pending the decision: for those who missed the deadline, submitting the application as soon as possible is still advisable.

Who pays CBAM, the importer or the non-EU supplier?

Formally the obligated party is the EU importer: they must register as an authorised declarant, submit the declaration and purchase the certificates. From an economic standpoint, the cost enters purchase prices and is transferred upstream or downstream based on bargaining power. Many supply contracts post-Reg. 2025/2083 include specific clauses on CBAM risk allocation between the parties.

What happens to CBAM after 2028?

CBAM grows in two directions. In terms of volume, free ETS allowances for CBAM sectors are progressively reduced until reaching zero in 2034: this means CBAM coverage rises year by year to 100%. In terms of scope, the legislative proposal of 17 December 2025 extends the mechanism to approximately 180 downstream steel and aluminium products from 1 January 2028. Other sectors (chemicals, refining, plastics) are being studied for subsequent phases.

Conclusion: CBAM compliance as an operational project

CBAM is no longer an abstract regulatory obligation: from 1 January 2026 it is operational, has a real price (€75.36/tCO₂ for Q1 2026), a precise declaration deadline (30 September 2027 for the first year), and a penalty system calibrated to European ETS market levels.

For those importing CBAM goods into Italy, compliance plays out on four fronts that must be managed together: mapping flows to understand whether one is above or below threshold and which CN codes are involved; clarifying authorisation status with MASE; structuring emissions data collection from non-EU suppliers, choosing between actual values and default values; integrating the CBAM cost into commercial contracts and 2026 economic projections, even though the actual certificate expenditure comes in 2027.

The most underestimated aspect is the emissions data: transforming non-EU supplier information into verifiable and defensible numbers for declaration requires a system that many companies do not have today. This is where, over the next 12-18 months, the difference lies between compliance suffered (with default values and 30% mark-up from 2028) and compliance managed (with verified actual values and controlled costs).

Atlas Carbon Neutral Solutions supports Italian importers in CBAM compliance with an MRV (Monitoring, Reporting, Verification) system that structures non-EU supplier emissions data into a verifiable and traceable format. Our architecture supports both default value calculations and structured collection of actual values ready for accredited verification.

Related articles

• Authorised CBAM declarant: how to obtain status from MASE
• 50-tonne CBAM threshold: who is exempt and how to monitor it
• CBAM embedded emissions calculation: 2026 methodology
• CBAM default values 2026: complete table by CN code
• CBAM certificates 2026: price, purchase, surrender
• Accredited verification vs CBAM default values: when each option pays off
• CBAM at customs: codes Y128, Y137 and operational procedures
• CBAM steel: impact on Italian importers
• CBAM cement: what changes for importers and clinker
• CBAM aluminium: declaration and calculation for importers
• CBAM penalties: €100/tonne and other operational risks
• CBAM 2028 extension: downstream steel and aluminium products

This article is for informational purposes only and does not constitute legal, customs or tax advice. Companies are invited to verify the most up-to-date regulatory references on official sources (OJEU, MASE, ADM) and consult with their trusted adviser for operational decisions. Updated: 4 May 2026.