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CBAM in 2026: what changes for importers into Portugal and the European Union

Regulation

Since 1 January 2026, importing certain goods into the European Union carries an environmental cost. The Carbon Border Adjustment Mechanism (CBAM) has left its transitional phase and entered the definitive period, under Regulation (EU) 2023/956, since amended by Regulation (EU) 2025/2083.

What CBAM is

CBAM makes importers of certain carbon-intensive goods bear the cost of the emissions embedded in those products, in line with what European producers already bear under the EU Emissions Trading System. It covers sectors such as cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.

Who must act: the authorised CBAM declarant

In the definitive period, only authorised CBAM declarants may import covered goods, subject to legal exceptions such as the de minimis exemption. In Portugal, an importer expecting to exceed the annual threshold of 50 tonnes of CBAM goods must apply beforehand for this status. Where obligations are assumed by an indirect customs representative, that representative must obtain the status before importation, even if the importer is not established in Portugal.

One point that causes confusion: having been a declarant during the transitional period does not make you an authorised declarant in the definitive period. They are separate processes.

Deadlines that matter

  • 31 March 2026: deadline to submit the authorisation request and keep importing provisionally. After 1 April 2026, anyone who had not applied lost that derogation.
  • 30 September 2027: due date of the first annual CBAM declaration, covering 2026 imports.

What to do now

  1. Check whether the tariff codes of your imports appear in Annex I of the regulation.
  2. Work out annual volume per good, to see whether it exceeds 50 tonnes.
  3. Ask suppliers for the embedded emissions data of their products, which you need for the declaration.
  4. If you import through a customs broker, confirm who holds the authorised declarant status.

For those buying steel, aluminium or fertilisers from suppliers outside the EU, CBAM becomes a cost to include in the purchasing decision, not just an administrative obligation. Comparing suppliers on ex-works price alone is no longer enough.

This article is for information only and reflects the information available at the date of publication. Customs legislation and procedures change often: always confirm the current version with the competent authorities or your customs broker before making decisions.

Cover photo: Aciarium, CC BY 4.0, Wikimedia Commons.

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