---
title: "CBAM and steel jerry cans: why HS 7310 is a listed good"
url: https://fortitude21.com/cbam-steel-containers-eu-import
language: en
description: "CBAM for steel jerry cans and containers: why HS 7310 is covered, declarant status from 2026, the 50-tonne threshold in units, and what to ask a supplier."
---

# CBAM and steel jerry cans: why HS 7310 is a listed good

Steel containers up to 300 litres sit in the CBAM annex. What the EU importer has to do, and the 50-tonne threshold that exempts most of them.

*The carbon sits in the steel, so the data has to come from the mill.*

A steel jerrican is a CBAM good. HS 7310 covers tanks, casks, drums, cans and similar containers of iron or steel up to 300 litres, and that heading sits in the CBAM annex. If you import steel containers into the EU, the carbon border mechanism applies to you.

**Quick answer:** Does CBAM apply to steel jerry cans?

Yes. Steel containers up to 300 litres fall under HS 7310, a heading listed in the CBAM annex; plastic containers are not covered. Since 1 January 2026, an EU importer of more than 50 tonnes of CBAM goods a year, counted across every heading and supplier, needs authorised CBAM declarant status before the goods clear.

## Why a jerrican is in scope

CBAM covers listed goods by customs heading rather than by end use, and iron and steel articles are on the list. **HS 7310** is the heading for steel containers up to 300 litres, whether or not lined or heat-insulated. A 20-litre pressed steel can classifies there, so it carries the same obligation as any other steel import even though nobody thinks of it as a steel product.

Plastic containers are not covered. Neither is aluminium packaging under this heading, though aluminium articles have their own CBAM entries, so check the heading rather than the material family.

The same physical can, described the same way in a catalogue, either carries a CBAM obligation or does not, depending on the heading it is entered under, and the importer is the party that declares it. A supplier's opinion about the code is useful background but gives no protection. Our [classification guide](https://fortitude21.com/tariff-classification-and-origin) sets out how the heading is arrived at and how to get a binding ruling on it.

The related trap is a mixed consignment. A pallet carrying steel cans, plastic cans and steel mounting brackets contains goods from three headings, two of which may be CBAM goods and one of which is not. The obligation attaches line by line rather than to the shipment, so an invoice that lumps everything into one description makes the declaration harder and the arithmetic against the threshold impossible. Ask for line-level weights by heading, not a total.

*Defaults carry a mark-up of 10 per cent in 2026, 20 per cent in 2027 and 30 per cent from 2028, each on the same underlying value, so the gap between real producer data and the default widens every year.*

## What the importer has to do

The definitive regime began on **1 January 2026**. From that date, an importer bringing in more than 50 tonnes of CBAM goods a year, or expecting to, needs the status of **authorised CBAM declarant**, applied for through the CBAM registry. This is a gate on import, not a report filed afterwards: above the threshold, without the status, the goods do not clear.

Authorisation is applied for and granted rather than declared, so it has a lead time and it sits in front of the first consignment rather than beside it. An importer discovering the requirement when a container is already on the water has a problem that money does not solve quickly, and the goods sit until the status exists.

- **Authorisation** through the CBAM registry, before importing.
- **Annual CBAM declaration**, with the deadline for the definitive period set at 30 September of the year following import.
- **CBAM certificates**, on sale from 1 February 2027 and surrendered by 30 September 2027, covering emissions embedded in 2026 imports.
- **Embedded emissions data** for the goods, either actual figures from the producer or the published default values.
- **Records**, kept so the declaration can be substantiated afterwards, since actual emissions must be verified and any declaration can be reviewed by the authorities.

## The threshold that exempts most container buyers

A mass-based de minimis of **50 tonnes per importer per year** exempts smaller volumes. For a container buyer that is a large number of cans, and it is worth doing the arithmetic before assuming you are caught.

| Format | Approximate empty weight | Units to reach 50 tonnes |
| --- | --- | --- |
| 20 L NATO-pattern steel fuel can | ~3.1 kg | ~16,000 per year |
| 20 L NATO-pattern steel water can | ~2.6 kg | ~19,000 per year |
| 10 L NATO-pattern steel can | ~1.8 kg | ~28,000 per year |

Calculated from our own published empty weights against the 50-tonne threshold. Indicative only: the threshold applies to your total CBAM-goods imports across all suppliers and headings, not to one product line, and steel accessories count too.

### Check your own imports

**1,704** cans a year, **5.3** tonnes of steel

Under the threshold: **5.3** tonnes of CBAM goods a year, or **11%** of 50 tonnes.

The container that takes you over 50 tonnes: **19**

Embedded emissions at the 2026 default: **24.8** t CO₂e a year

Container counts are our factories’ loading figures for each can, unpalletised in a 20ft container. Defaults are the 2026 values for CN 7310 including the mark-up. Below 50 tonnes a year in total the importer has no CBAM obligation for these goods; above it, authorised declarant status is needed. Indicative only.

A distributor bringing in a container or two of steel cans a year sits well under the threshold. A national importer running steel across several lines can cross it without noticing, because the 50 tonnes is cumulative across everything they import in scope.

*Units per year to reach 50 tonnes, from our own published empty weights. The threshold counts ALL your CBAM goods across every heading and supplier, not one product line, so a multi-line importer crosses it sooner than this suggests.*

## Default values, and why they get worse

Where actual producer emissions data is not available, importers use published default values. Default values are set per product code and per country of production. For a steel container under CN 7310 in 2026, including the mark-up, the figure is about **4.7 tonnes CO₂e per tonne** of goods from China and about 2.6 from Viet Nam. Those defaults are set to rise on a schedule, by roughly 10 per cent in 2026, 20 per cent in 2027 and 30 per cent in 2028. The rise is deliberate: it pushes importers to obtain real emissions data from the producer instead of defaulting.

On a 20-litre steel jerry can weighing 3.1 kg, that comes to about 14.6 kg CO₂e if the can is made in China and about 8 kg if it is made in Viet Nam.

A supplier who can give you verified embedded-emissions figures becomes cheaper than one who cannot, without changing the price of the can, because the default carries a penalty that grows every year.

Ask for the data now rather than later. Default values exist so that trade is possible without producer data, and they are set to be unattractive by design, so the gap between a default and a verified figure widens as the mechanism phases in. A supplier who cannot produce embedded-emissions data today sells goods that get relatively more expensive every year. That makes it a sourcing question.

*Scope follows the heading rather than the material family, so accessories have to be checked on their own rather than inherited from the container they serve. A mixed pallet contains goods from several headings and the obligation attaches line by line, which is why line-level weights by heading matter more than a shipment total.*

## Who pays for CBAM certificates?

The authorised CBAM declarant pays: the EU importer that lodges the customs declaration in its own name. The declarant can instead be an indirect customs representative that lodges the declaration for the importer and agrees to act as declarant (Regulation (EU) 2023/956, Articles 3(15) and 5, as amended by Regulation (EU) 2025/2083).

Where the importer is not established in an EU Member State, the indirect customs representative must hold the status itself.

The producer outside the EU pays nothing to the EU. Its part is the evidence. Where the importer declares actual emissions, the plant supplies a verified operator’s emissions report on the Commission’s template, through the CBAM registry or direct, and the Commission’s Guidance No. 2 for non-EU operators explains that the template is mandatory. That report is what a CBAM supplier questionnaire is asking for. It is a separate document from the design-type certificate covered in our [UN approved packaging guide](https://fortitude21.com/un-approved-packaging), which shows the can passed its performance tests and says nothing about carbon.

The money then moves in four steps:

1. The declarant works out the certificates due.
2. It buys them on the common central platform that Member States use from 1 February 2027 (Article 20).
3. It surrenders them through the CBAM registry by 30 September for the previous calendar year (Article 22(1)).
4. It can ask by 31 October for any surplus to be bought back at the price it paid (Article 23).

*The producer outside the EU is not on this path: it supplies the verified emissions data and pays nothing to the EU.*

Two rules bring the cash forward. An applicant that was not established throughout the two financial years before it applied must lodge a guarantee worth the certificates it expects to surrender (Article 17(5)). From 2027 the declarant must also hold certificates at the end of each quarter for at least 50% of the embedded emissions imported since 1 January. Those emissions are counted at the default values without the mark-up, or on last year’s surrender for the same goods and origins, after the free allocation adjustment (Article 22(2)).

## How the CBAM certificate price is set

The European Commission sets the price from EU ETS auctions: the average auction clearing price of the allowances sold, weighted by the volume of each auction (Implementing Regulation (EU) 2025/2548, Articles 1 and 5). One certificate covers one tonne of CO₂e. For goods imported in 2026 the price is the average for the quarter of import (Article 21(1a) of the CBAM Regulation), published early in the following quarter. From 2027 the Commission publishes a weekly average on the first working day of the next week, and that price applies to certificates bought until the next one replaces it.

| Quarter of import | Published | Price per certificate |
| --- | --- | --- |
| Q1 2026 | 7 April 2026 | €75.36 |
| Q2 2026 | 6 July 2026 | €75.28 |
| Q3 2026 | 5 October 2026 | €82.32 |
| Q4 2026 | Due 4 January 2027 | Not yet published |

From the European Commission’s price page, read on 19 October 2026. Under Implementing Regulation (EU) 2025/2548 the Commission is the only publisher of the CBAM price.

The 2026 rules leave a gap between import and payment. A can landed in March 2026 is priced at the Q1 figure, but no certificate can be bought before 1 February 2027, and the declaration and surrender fall due on 30 September 2027. Certificates bought for 2026 imports can be sold back only in 2027, and any left on the account on 1 November 2027 are cancelled without compensation (Articles 23(2a) and 24(2)).

*Q2 2026 was €75.28 and Q3 €82.32; the Q4 price is due on 4 January 2027. Requests to sell back surplus close on 31 October.*

*An importer discovering this with a container on the water has a problem money does not solve quickly, because the third box will not run until the second one has.*

## What CBAM costs on a container of steel jerry cans

Certificates due equal the embedded emissions, minus a free allocation adjustment, minus any reduction for a carbon price paid where the goods were made (Regulation (EU) 2023/956, Article 6(2)(c)). The adjustment mirrors the free allowances EU steelmakers still receive. With default values it is the mass imported, times the default CBAM benchmark for the CN code, times the CBAM factor for the year, times a cross-sectoral correction factor (Implementing Regulation (EU) 2025/2620, Annex). The CBAM factor is 97.5% in 2026 and reaches zero in 2034 (Directive 2003/87/EC, Article 10a(1a)), and the correction factor is 100% for every year from 2026 to 2030 (Implementing Decision (EU) 2026/1862).

The phase-out applies to the benchmark. In 2026 the importer pays for every tonne above 97.5% of the benchmark, so a high default value goes almost straight into the certificate count.

Take one 20ft container of our 20 L steel fuel cans: 852 cans at 3.1 kg, or 2.641 tonnes, from our [container loading figures](https://fortitude21.com/container-loading-drums-ibcs-jerry-cans). Two inputs are illustrations, not a forecast. The emissions intensity is the 2026 default for heading 7310 in Implementing Regulation (EU) 2025/2621, which the checker above rounds to 4.7 and 2.6; a verified mill figure would replace it. The certificate price is a round €80, near the 2026 quarterly prices so far. The default CBAM benchmark for these cans, on the blast-furnace route the defaults assume for both countries, is 1.491 t CO₂e per tonne.

| One 20ft container, imported in 2026 | Made in China | Made in Viet Nam |
| --- | --- | --- |
| Default value with the 10% mark-up | 4.743 t CO₂e per tonne | 2.607 t CO₂e per tonne |
| Embedded emissions in 2.641 t of cans | 12.53 t CO₂e | 6.89 t CO₂e |
| Free allocation adjustment: 2.641 × 1.491 × 97.5% | 3.84 t CO₂e | 3.84 t CO₂e |
| Certificates due | 8.69 | 3.05 |
| Cost at an illustrative €80 | About €695 | About €244 |

The Viet Nam count is about a third of China’s although its default is a little over half, because the same 3.84 tonnes comes off both and every extra tonne of default emissions is paid in full. That puts the country of production into landed cost, next to the duty and approval points in our [second sourcing guide](https://fortitude21.com/second-sourcing-and-china-plus-one). Three things change the figure. A verified actual value from the mill replaces the default, and the deduction then follows the production route the mill uses. A carbon price paid where the steel was made reduces the count. With default values it applies only against a yearly default carbon price, which the Commission may publish for a country from 2027. With actual values it applies only where payment is documented and certified by an independent person (Article 9). And the calendar moves it, as the CBAM factor drops to 95% in 2027 and 90% in 2028 while the default mark-up rises to 20% and then 30%.

*CBAM factor from Article 10a(1a) of the EU ETS Directive. The correction factor is 100% for 2026 to 2030; later years are not yet set.*

*The obligation attaches line by line rather than to the shipment. An invoice that lumps a mixed pallet into one description makes the threshold arithmetic impossible, so ask for line-level weights by heading.*

## What to ask a supplier for

- The customs heading the goods classify under, confirmed rather than assumed
- Net weight per unit and per shipment, so you can track against the 50-tonne threshold
- Embedded emissions data for the steel, if the producer holds it
- Country of production, since CBAM interacts with origin

## Where we stand on this

We publish empty weights per unit, which is what you need for the threshold arithmetic, and we confirm the customs heading for any product before you order. **Verified embedded-emissions data is not attached to our standard range today. It is obtainable, and where CBAM reporting is a programme requirement we source the run from a mill that can supply it.**

Embedded emissions are a property of the steel and the mill that made it, not of the pressing operation, so the data has to come from upstream. The mill is therefore a sourcing decision, and it has two consequences:

- **Raise it at enquiry, not after.** It determines which mill the coil comes from, which is settled before production rather than during it.
- **It is worth money as the defaults escalate.** The mark-up on default values rises from 10 per cent in 2026 to 30 per cent from 2028, so verified figures pull further ahead of the default each year. A run sourced with verified figures gets cheaper against the alternative without the can changing at all.

If you are under the 50-tonne threshold, you declare the exemption on the customs declaration, the rest of this does not apply, and the empty weights above are all you need. If you are over it, or expect to be, tell us and we will quote the mill route alongside the standard one so you can see what the data costs against what the default costs.

*The escalation is deliberate. A supplier who cannot produce embedded-emissions data is a supplier whose goods get relatively more expensive every year without the price of the can changing at all.*

## Where to start

| Your use case | Recommended can | Why this one |
| --- | --- | --- |
| Steel into the EU | [20L NATO Steel Fuel Can](https://fortitude21.com/product-20l-nato-steel-fuel-can) | HS 7310, empty weight published for threshold maths. |
| Stainless, still steel | [20L Stainless Steel Water Can](https://fortitude21.com/product-20l-stainless-water-can) | Same heading family; check before you assume. |
| Outside CBAM entirely | [Economy HDPE Jerrycan — non-UN](https://fortitude21.com/product-economy-hdpe-jerrycan) | Plastic containers are not listed goods. |
| Volume plastic for the EU | [25L Stackable Plastic Jerrycan](https://fortitude21.com/product-25l-plastic-lring-jerrycan) | No CBAM, but PPWR and EPR still apply. |

## Common questions

### Are jerry cans covered by CBAM?

Steel ones are. CBAM lists goods by customs heading, and HS 7310 covers tanks, casks, drums, cans and similar containers of iron or steel up to 300 litres. A steel jerrican classifies there, so it carries the same obligation as any other steel import. Plastic containers are not listed goods.

### What does an EU importer of steel containers have to do under CBAM?

Above the 50-tonne threshold, hold authorised CBAM declarant status, applied for through the CBAM registry, before importing. The definitive regime began on 1 January 2026 and the status is a gate on import rather than a report filed afterwards. An annual CBAM declaration follows, with certificates on sale from February 2027 and surrendered by 30 September 2027 for 2026 imports.

### Is there a minimum threshold before CBAM applies?

Yes, a mass-based de minimis of 50 tonnes per importer per year. For 20 litre steel cans at roughly 3.1 kg empty that is about 16,000 units annually, but the threshold counts all your CBAM goods across every heading and supplier, not one product line.

### What are CBAM default emissions values for steel?

They are set per product code and country of production, and used where the importer declares no verified actual figure. For heading 7310 the underlying value is 4.312 tonnes of CO2e per tonne of goods from China and 2.370 from Viet Nam.

A mark-up on that underlying value applies: 10% in 2026, 20% in 2027 and 30% from 2028. That gives 4.743, 5.174 and 5.605 for China, and 2.607, 2.844 and 3.081 for Viet Nam, which pushes importers towards verified producer data.

### What is the difference between CBAM and the EU ETS?

The EU ETS prices the emissions of installations inside the EU, which surrender allowances that are capped, partly auctioned and traded. CBAM puts the same carbon price on the emissions embedded in listed goods imported into the EU, through certificates the importer buys at a price the Commission takes from ETS auction clearing prices.

As EU producers lose their free ETS allowances between 2026 and 2034, the CBAM free allocation adjustment shrinks in step, so imported and EU-made goods carry the same carbon cost.

### Does CBAM count the electricity used to make steel?

No. For most iron and steel goods, including heading 7310, and for aluminium and hydrogen, only direct emissions count: Annex II of Regulation (EU) 2023/956 lists them, and the 2025 amendment added imported electricity to that list. Indirect emissions, meaning emissions from the electricity consumed in production, are added for cement and fertilisers.

For a steel jerry can, the declaration counts the direct emissions of the steelworks and of the plant that presses and welds the can.

### Does the UK CBAM give relief for a carbon price paid overseas?

Yes. Under the UK CBAM, which starts on 1 January 2027, the liable person can claim carbon price relief where the goods were subject to a qualifying carbon pricing scheme abroad. The relief is subtracted from the CBAM charge and cannot exceed it, and the claim needs a carbon pricing verification form completed by an independent accredited verifier.

HMRC’s policy summary says the UK rate reflects the UK ETS price after free allocation and is published at the start of each quarter.

### What happens if an importer does not surrender enough CBAM certificates?

It pays a penalty for each missing certificate and still owes the certificates. Article 26 of the CBAM Regulation sets the penalty at the EU ETS excess emissions penalty for the year of import, which is €100 a tonne raised in line with the European index of consumer prices.

A person who imports CBAM goods without authorised declarant status, including an importer that passes the 50-tonne threshold without it, faces three to five times that amount per certificate.

### What is the CBAM registry?

It is the European Commission’s IT system for the definitive regime. Authorised declarants hold their accounts there, submit the annual declaration and manage the certificates they buy and surrender. An importer requests access through the national competent authority of the EU country where it is established.

Producers outside the EU can register their installations in the registry’s operator module and share verified emissions data with every importer of their goods, who then sees a summary rather than the full report.

### Where can I read the CBAM regulation?

On EUR-Lex. The base text is Regulation (EU) 2023/956, amended by Regulation (EU) 2025/2083, and a consolidated version dated 20 October 2025 combines the two. The working detail sits in Commission implementing regulations: 2025/2547 on calculating embedded emissions, 2025/2548 on the certificate price, 2025/2620 on the free allocation adjustment and 2025/2621 on default values, corrected by 2026/1740.

The Commission lists each act on its CBAM legislation and guidance page.

### What does CBAM mean?

CBAM stands for Carbon Border Adjustment Mechanism. The EU version, set up by Regulation (EU) 2023/956, makes the importer pay for the carbon emitted in producing certain goods abroad, matching the carbon price EU producers pay under the EU Emissions Trading System.

The UK runs its own, separate CBAM from 1 January 2027. Both cover iron and steel, so a steel jerry can entered under heading 7310 is caught by each.

### How does CBAM work?

CBAM puts a price on the carbon emitted in making the imported goods. The importer works out those embedded emissions, from verified producer data or the published default values, and surrenders one CBAM certificate for each tonne of CO2 equivalent.

Certificates are priced from EU ETS allowance auctions: a quarterly average for 2026 imports and a weekly average after that. A carbon price already paid in the country of production reduces the number due, and so does the free ETS allocation EU producers still receive.

### Is CBAM a tax or a tariff?

The EU treats it as neither. CBAM is a carbon pricing measure adopted under the environment article of the EU treaties, Article 192(1) TFEU, and paid through certificates for the emissions embedded in the goods, priced from the EU Emissions Trading System.

In practice it adds a carbon cost to the import on top of any customs duty. The UK version, which starts on 1 January 2027, is a tax charged at a CBAM rate on the emissions embodied in the goods.

### Is CBAM in effect?

Yes. The EU CBAM ran a transitional period from 1 October 2023 to 31 December 2025, when importers only reported emissions. The definitive regime has applied since 1 January 2026, so goods imported now create a financial obligation, settled by surrendering certificates in 2027 for 2026 imports.

An importer bringing in no more than 50 tonnes of CBAM goods a year is exempt. The UK runs a separate CBAM from 1 January 2027.

### Does CBAM apply in the UK?

The EU CBAM covers imports into the EU, so it does not apply to goods entering Great Britain. The UK runs its own CBAM from 1 January 2027, across the whole UK including Northern Ireland. It covers aluminium, cement, fertiliser, hydrogen, and iron and steel, and its goods list includes heading 7310, so steel jerry cans are in scope.

The importer is liable above a £50,000 registration threshold, and the first return and payment are due on 31 May 2028.

### Does CBAM apply to aluminium?

Yes. Aluminium is one of the CBAM sectors, alongside cement, iron and steel, fertilisers, electricity and hydrogen. Annex I of the regulation lists unwrought aluminium and a run of aluminium articles, including heading 7612 for aluminium casks, drums, cans and boxes and 7616 for other articles of aluminium.

An aluminium jerry can sits outside 7310, the steel heading, but an aluminium container heading is on the list as well, so check the heading before treating the can as exempt.

### Does CBAM apply to finished goods?

Only to finished goods listed in Annex I of the CBAM Regulation. Most of the list is basic material, but some steel and aluminium articles are in: 7310 steel containers, 7326 other articles of iron or steel, 7612 aluminium containers and 7616 other articles of aluminium.

Plastics are not covered. In December 2025 the European Commission proposed adding about 180 steel- and aluminium-intensive downstream products from 1 January 2028, and that proposal is still going through the EU legislative process.

### Why is CBAM needed?

To stop carbon leakage. EU producers of steel, aluminium, cement and the other covered goods pay for their emissions under the EU Emissions Trading System. Without a border measure, production could move to countries with weaker carbon pricing and the emissions would relocate instead of falling.

CBAM charges imports an equivalent carbon price. Its charge phases in from 2026 in step with the withdrawal of the free ETS allowances EU producers receive, which runs until 2034.

## References

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

- [European Commission: Carbon Border Adjustment Mechanism](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en)
- [Regulation (EU) 2023/956: establishing a carbon border adjustment mechanism](https://eur-lex.europa.eu/eli/reg/2023/956/oj)
- [Regulation (EU) 2025/2083: simplifying the CBAM, including the 50-tonne threshold](https://eur-lex.europa.eu/eli/reg/2025/2083/oj)
- [Implementing Regulation (EU) 2025/2621: CBAM default values](https://eur-lex.europa.eu/eli/reg_impl/2025/2621/oj)
- [UN Model Regulations on the Transport of Dangerous Goods (Rev. 24)](https://unece.org/transport/dangerous-goods/un-model-regulations-rev-24)
- [World Customs Organization: rules of origin](https://www.wcoomd.org/en/topics/origin.aspx)
- [Commission Implementing Regulation (EU) 2025/2548 on the calculation and publication of the price of CBAM certificates, European Commission, 2025](https://eur-lex.europa.eu/eli/reg_impl/2025/2548/oj)
- [Price of CBAM certificates (quarterly prices for 2026), European Commission, Directorate-General for Taxation and Customs Union, 2026](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en)
- [Commission Implementing Regulation (EU) 2025/2620 on the calculation of the free allocation adjustment to the number of CBAM certificates to be surrendered, with the CBAM benchmarks, European Commission, 2025](https://eur-lex.europa.eu/eli/reg_impl/2025/2620/oj)
- [Directive (EU) 2023/959 amending Directive 2003/87/EC (EU ETS), setting the CBAM factor in Article 10a(1a), European Parliament and Council, 2023](https://eur-lex.europa.eu/eli/dir/2023/959/oj)
- [Commission Implementing Decision (EU) 2026/1862 determining the uniform cross-sectoral correction factor for 2026 to 2030, European Commission, 2026](https://eur-lex.europa.eu/eli/dec_impl/2026/1862/oj)
- [Directive 2003/87/EC establishing the EU Emissions Trading System, consolidated text, Article 16(3) excess emissions penalty, European Parliament and Council](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02003L0087-20240301)
- [Guidance No. 4: CBAM calculation of the free allocation adjustment to the number of CBAM certificates to be surrendered, European Commission, August 2026](https://taxation-customs.ec.europa.eu/document/download/3aa2c730-4f1b-4524-8f71-d9cfe4880ac7_en)
- [Guidance No. 2: Quick guide for non-EU operators on CBAM implementation, European Commission, August 2026](https://taxation-customs.ec.europa.eu/document/download/91e1056c-4524-4705-aaa7-e25c1439a87a_en)
- [CBAM legislation and guidance, including default values and benchmarks, European Commission, Directorate-General for Taxation and Customs Union, 2026](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en)
- [Carbon Border Adjustment Mechanism (CBAM): Policy summary, HM Revenue and Customs, GOV.UK, updated 16 October 2026](https://www.gov.uk/government/publications/carbon-border-adjustment-mechanism-cbam-policy-summary/carbon-border-adjustment-mechanism-cbam-policy-summary)

First published 12 August 2026

Last reviewed 21 October 2026 by [Clarence Cheang](https://fortitude21.com/clarence-cheang), Co-Founder & COO. [How we review our guides](https://fortitude21.com/editorial-policy) Fortitude21 makes and sells liquid containers; our guides carry no affiliate links.