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Lakshmikumaran and Sridharan attorneysNavigating CBAM

Fundamentals

What is CBAM (the EU Carbon Border Adjustment Mechanism)?

The EU Carbon Border Adjustment Mechanism in plain language: what it covers, who it binds, and the cost it puts on embedded emissions in imported goods.

This page covers the EU Carbon Border Adjustment Mechanism under Regulation (EU) 2023/956. It does not cover the UK's separate carbon border regime.

By Lakshmikumaran and Sridharan attorneysReviewed by LKS CBAM editorial team
Last reviewed: June 2026
On this page
  1. Direct answer
  2. Why CBAM exists
  3. What it covers today
  4. Who must comply
  5. Transitional and definitive phases
  6. FAQ
  7. What to read next

Direct answer

CBAM is an EU mechanism that puts a carbon price on selected imports equivalent to the price paid by EU producers under the EU Emissions Trading System. It applies to imports of cement, iron and steel, aluminium, fertilisers, hydrogen, and electricity.

Why CBAM exists

The EU has tightened its domestic carbon constraint through the EU ETS. Without a corresponding measure on imports, production could shift to jurisdictions with weaker climate policy, a concern known as carbon leakage. CBAM addresses this by pricing the embedded emissions of imported goods at the same level that EU installations pay.

What it covers today

  • Cement
  • Iron and steel and selected downstream products
  • Aluminium and selected downstream products
  • Fertilisers
  • Hydrogen
  • Electricity

Who must comply

The legal obligation sits with the importer of record into the EU, acting through an authorised CBAM declarant. Non-EU producers and installation operators do not file CBAM returns themselves, but they are usually the only party able to supply verified emissions data their EU customers need.

Transitional and definitive phases

The transitional phase ran from 1 October 2023 to 31 December 2025, with quarterly reporting and no financial obligation. The definitive phase starts 1 January 2026; from that date imports of covered goods may only be made by authorised CBAM declarants, and from 2027 onwards declarants must surrender CBAM certificates against the emissions declared for the previous year.

Frequently asked questions

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What to read next

Source: Navigating CBAM by Lakshmikumaran and Sridharan Attorneys. Canonical: https://cbam.lkslaw.com/what-is-cbam (ref 016vswj). Reuse permitted under the site terms with attribution and a link back.

Discuss this topic with our international trade and customs practice: write to ankur.sharma@lakshmisri.com.