CBAM moved from reporting to paying on 1 January 2026, and it has raised a question we hear from buyers who also purchase voluntary credits: can those credits lower the CBAM bill?
They cannot. CBAM is a compliance charge on imported goods, and the regulation only accepts a carbon price paid in the producing country as a deduction. This article explains how CBAM works, who pays, what it costs in 2026, and how it relates to a voluntary carbon credit budget.
What CBAM is and why it exists
The EU ETS puts a price on the emissions of EU steel, cement, aluminium and fertiliser plants (EU ETS explained). Until now those sectors received most of their allowances for free, to protect them against competitors in countries without a carbon price. That free allocation is being phased out: the factor for CBAM sectors falls from 97.5% in 2026 to 14% in 2033 and to zero from 2034.
CBAM replaces that protection at the border. An importer pays roughly what an EU producer would pay for the same emissions, so production does not simply move outside the EU (carbon pricing explained).
Who has to pay
Goods covered: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, including a list of products made from them, such as screws, bolts and some steel and aluminium structures.
Threshold: since the 2025 simplification, importers of no more than 50 tonnes a year of steel, aluminium, cement and fertilisers together are exempt. If you exceed 50 tonnes at any point in the year, all your imports for that year fall under CBAM. Electricity and hydrogen have no threshold.
Who acts: the importer, or its indirect customs representative, must be an authorised CBAM declarant before importing above the threshold.
How the charge works
Embedded emissions are calculated per product, preferably from actual data of the producing installation, otherwise from default values that the Commission sets on the high side.
Certificates cover those emissions, one per tonne of CO2 equivalent. For 2026 the price is set per quarter from EU ETS auction prices: €75.36 for the first quarter and €75.28 for the second quarter, published on 6 July 2026 (European Commission).
Adjustments reduce the number of certificates: one for the free allocation EU producers still receive, and one for a carbon price effectively paid in the country of origin.
Timing: certificates for 2026 imports go on sale from February 2027, and the first annual declaration and surrender are due by 30 September 2027.
For a sense of scale: an importer bringing in 1,000 tonnes of steel with 2 tonnes of embedded CO2 per tonne would need certificates for 2,000 tonnes, minus the adjustments. At the Q2 2026 price, that is about €150,000 before the free allocation adjustment. The real figure depends on the product, its production route and the data the supplier provides.
Do carbon credits reduce CBAM?
No. The CBAM Regulation allows a deduction only for a carbon price paid in the country of production, which it defines as a tax, levy, fee or emission allowances under a trading system (Regulation (EU) 2023/956). Voluntary carbon credits, whether bought by the importer or the foreign producer, are not on that list.
That has three practical consequences:
Keep the budgets apart. CBAM is a cost of importing, like a duty. Your voluntary credit budget supports your climate claims and your remaining emissions (what a carbon offset is).
Lower CBAM by lowering embedded emissions. Suppliers with real installation data and lower-carbon production, such as electric arc furnace steel, reduce the bill more than any credit can.
Count CBAM goods in your Scope 3. Imported steel or aluminium sits in purchased goods, Scope 3 category 1. Paying CBAM does not remove those emissions from your footprint (Scope 3 and carbon credits).
Tip from Bernard de Wit, Founder of Regreener: “When a supplier offers to 'offset' the CBAM emissions of a shipment with credits, the offer is worth nothing for your CBAM declaration. Ask the supplier for verified installation data instead. That is the number that lowers your certificates.”
What is changing next
On 17 December 2025 the Commission proposed extending CBAM to about 180 downstream products that contain steel and aluminium, such as machinery parts and appliances, and adding rules against circumvention. The proposal is still with the Parliament and the Council. If you buy finished products with a high steel or aluminium content from outside the EU, it is worth checking now which of them could fall under the extended scope.
“For most of our clients CBAM is a procurement and customs topic, not a carbon credit topic. Where it meets our work is the climate budget. A company paying CBAM has a carbon cost on its imports, and the board should see that next to what it spends on credits.”
Bernard de Wit, Founder of Regreener
Want to see CBAM next to your carbon credit budget?
Talk to us about how CBAM, Scope 3 and your credit purchases fit in one climate budget.
