CBAM Definitive Period 2026: What Steel Exporters Must Do

CBAM's transitional period (October 2023 to December 2025) only asked for reports; since 1 January 2026 the definitive period has been running and embedded emissions carry a cost. The liable party is the EU importer, but the data it declares comes from the steel plant in Türkiye. A producer who supplies no data is priced at default values, and that feeds straight into purchasing decisions.

CBAM and the DPP described the two regimes' shared data layer. This article covers the 2026 calendar and the steel producer's delivery list.

What changed in the definitive period

The transitional period meant quarterly reports, wide use of default values and no payment. The definitive period changes three things: the declaration becomes an annual, formal obligation; actual data needs an accredited verifier's confirmation; and CBAM certificates are surrendered against the declared emissions. The certificate price tracks the EU ETS; the obligation starts small, in step with the phase-out of free allocation, and reaches full load by 2034.

The 2025 simplification package softened this at two points: a 50-tonne annual mass threshold per importer replaced the per-consignment value threshold, and certificate purchases moved back a year. The scope did not change: iron and steel products from billets and sections to rolled products and fasteners stay listed; scrap is outside.

Who does what

In short: legal liability and commercial cost sit with the importer, data production with the producer. Your customer will want to share that cost with you, at least when comparing offers; for operator roles see the DPP roadmap for Turkish exporters.

The producer's delivery list

1. Draw the installation boundary. Which processes make which CN-coded product; set the allocation rule for shared installations.
2. Calculate direct emissions. Fuel, process emissions and the embedded emissions of purchased precursors (billets, hot metal, DRI) are added up under the CBAM methodology; for iron and steel, direct emissions are the basis.
3. Choose a verifier. Actual data is valid with an accredited verifier's report; plan verification around the production year's close.
4. Register in the CBAM registry. Third-country operators can upload installation data and share it with their importers, safer than a separate spreadsheet per customer.
5. Prepare the carbon-price document. Türkiye's national emissions trading system is being set up; a carbon price actually paid in the country of origin is deductible from the importer's obligation, and you will be asked for the proof.
6. Map the same data onto passport fields. Route, scrap share and emissions per tonne become the passport's core fields once the delegated act arrives: steel DPP data fields.

The default-value trap

Default values apply when no actual data is submitted and are set, by design, to encourage actual data. For an electric-arc-furnace plant this can mean being priced well above its own emissions: not supplying data costs more than producing it.

A secondary effect: the importer prefers suppliers with verified actual data, because its own declaration and certificate cost depend on it; data quality becomes a competitive factor. On measurement versus default factors see primary and secondary data.

Where customs and the passport meet

The CBAM declaration is tied to the customs declaration: without the importer's authorised declarant number, CBAM goods cannot enter free circulation. As delegated acts take effect, customs will also check the passport's registry record on the same shipment; one product identity serves both checks. See DPP checks at customs and the DPP for iron and steel.

Cement exporters face the same logic, with indirect emissions in scope too; see DPP for cement and concrete. For a cross-sector roadmap see the Turkish exporter guide and the CBAM tag.

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