CBAM from 2026: A practical guide for Czech importers

When you don't have to deal with anything anymore – and when, on the contrary, there is a risk of a problem
  • In the CBAM transitional period in 2023-2025, most importers were primarily faced with the obligation to report quarterly in the transitional CBAM register. However, from 2026 onwards, the mechanism enters its definitive phase, bringing fundamental changes in the scope of the obligations and in their practical impact. These changes affect smaller importers the most.
  • Based on the experience of the transitional period, a new Regulation (EU) 2025/2083 was adopted on 8 October 2025, which modifies the original CBAM rules. The aim of the amendment is to reduce the administrative burden where it would be disproportionate, while preserving the environmental sense of the entire system.
Imports up to 50 tonnes: when the CBAM does not apply at all
  • The most common question that importers turn to advisors with is whether they have to deal with the CBAM even if their annual import volume does not exceed 50 tonnes. The amendment gives an unambiguous answer to this question.
  • If an importer does not exceed 50 tonnes of CBAM goods per calendar year and at the same time does not import electricity or hydrogen, the so-called de minimis exemption applies to him. In such a case, the importer is completely excluded from the scope of the CBAM. It does not have to apply for the status of an approved CBAM declarant, does not register in the CBAM Registry, does not submit CBAM declarations, does not purchase or submit CBAM certificates, and does not deal with the calculation or verification of emissions. In other words, in the definitive period, the CBAM will not apply to him at all.
  • However, it is important to emphasize that this exemption does not apply to imports of electricity and hydrogen. For these commodities, the CBAM applies regardless of quantity, even for very small import volumes.
Importer up to 50 tons per year:
  • it does not have to have the status of an approved CBAM declarant,
  • does not register in the CBAM Registry,
  • does not submit a CBAM declaration,
  • does not purchase or hand over CBAM certificates,
  • It does not deal with the calculation or verification of emissions.
! NOT applicable to electricity and hydrogen, where the CBAM applies regardless of the quantity imported.

Exceeding the 50-tonne threshold: the tipping point
  • A crucial moment is when the importer exceeds the limit of 50 tons during the year. In such a case, the CBAM will not only apply to imports above the limit, but to all imports made in a given calendar year.
  • This means that the importer must retroactively comply with all CBAM obligations, including obtaining the status of an approved CBAM declarant, filing an annual CBAM declaration, and subsequently settling the certificates. If the limit is exceeded without the necessary approval, it can lead to the suspension of imports and the imposition of sanctions.
  • For this reason, it is crucial to monitor the volume of imports on an ongoing basis and to address the status of an approved declarant well in advance if the importer is approaching or likely to exceed the 50-tonne limit.
Status of approved declarant and transitional arrangement for 2026
  • At the same time, the amendment introduces a practical transitional measure for 2026. If an importer submits an application for the status of an approved CBAM declarant by 31 March 2026 at the latest, he may continue importing until the application is decided, if the limit of 50 tonnes is exceeded. This measure provides importers with a certain time buffer, but does not replace the obligation to prepare in time.
Postponement of deadlines: relief only at first sight
  • The amendment also brings changes to key deadlines. The annual CBAM declaration is now submitted until 30 September of the following year, the first purchase of CBAM certificates will take place in February 2027 and their first submission by 30 September 2027. Therefore, certificates are not purchased in 2026.
  • This shift may create the impression that there is no need to actively address CBAM in 2026. However, this impression is misleading. The amount of the obligation in 2027 will be based on the emissions actually included in imports made in 2026. If the emission data are not set correctly and systematically monitored from the beginning of the year, they cannot be reconstructed retrospectively at the end of the year.
Changes in deadlines and certificates – at a glance
  • Annual CBAM declaration: newly by 30 September of the following year (e.g. for 2026 → by 30.9.2027)
  • First purchase of CBAM certificates: February 2027
  • First submission of certificates: by 30/09/2027
  • Year 2026: certificates are not bought, data is collected
Why 2026 is crucial
  • From the CBAM's point of view, 2026 is a period of data collection and preparation. It is in this year that it is necessary to set  the so-called CBAM emission baseline, i.e. the initial emission profile of imports, which serves as a reference point for calculating the future obligation. At the same time, it is advisable to work with emission forecasting, i.e. a realistic estimate of the future development of emissions based on planned import volumes.
  • Although emission forecasting is not mandatory, it is an important risk management tool. It allows for better planning of the financial impacts of the CBAM, anticipating the need for certificates and identifying in time situations where there could be a significant increase in the emission burden.