From 2026, the EU's new Carbon Border Adjustment Mechanism applies in full, and for importing SMEs in Sweden it means potentially new costs, new administrative requirements, and a need to understand how much carbon is actually embedded in what you buy.

What is CBAM?

CBAM – Carbon Border Adjustment Mechanism – is an EU regulation that came into force in 2023 and entered its definitive phase on 1 January 2026.[¹] Simply put: it is a system designed to put a price on the carbon embedded in imported goods, equivalent to the price EU producers already pay through the EU Emissions Trading System (EU ETS). It is not a traditional tariff on the value of goods – but a carbon charge on the emissions behind them.

The purpose is twofold: to prevent "carbon leakage" – where emissions-intensive production moves outside the EU to avoid carbon costs – and to ensure that goods imported into the EU do not compete with an unfair advantage over European producers who already bear the cost of their emissions. Swedish importers will thus pay a similar carbon price to the one European producers already pay.

Which goods and sectors does CBAM cover?

CBAM applies to goods imported into the EU across six sectors:

1. Iron and steel

2. Aluminium

3. Cement

4. Fertilisers

5. Electricity

6. Hydrogen

These sectors were selected because they are particularly emissions-intensive and have a high risk of carbon leakage. The EU has also announced a review of whether additional sectors and downstream goods could be included from 2028.[²]

Important to note: it is not the sector you operate in that determines whether CBAM affects you – it is what you import. A manufacturing company in Sweden that buys in steel from Turkey is affected. A construction firm importing aluminium profiles from China is also affected. If your imports do not include these product categories – or if the goods come from the EEA (Norway, Iceland, Liechtenstein) or Switzerland, which have equivalent carbon pricing systems – you are exempt.[¹]

Three phases: reporting, then payment

CBAM has been rolled out in stages:

• Transitional phase (October 2023 – December 2025): Importers were required to report quarterly on embedded emissions in imported goods, but no payments were required. The purpose was to gather data and prepare the system for the definitive phase.[³]
• Definitive phase (from 1 January 2026): Financial obligations now apply in full. Importers exceeding the threshold must apply for authorised CBAM declarant status and collect verified emissions data for 2026 imports. Certificates are purchased and surrendered in arrears: sales open in February 2027 and certificates for the 2026 financial year must be submitted by 30 September 2027.[¹][¹⁰]

The certificate price for Q1 2026 was set by the European Commission at €75.36 per tonne of CO₂e – a price reflecting the volume-weighted average of EU ETS auctions during the period.[⁴] The price will be updated quarterly during 2026, and weekly from 2027 onwards.

The 50-tonne threshold – the key for SMEs

The most important development for importing SMEs came with the EU's Omnibus package, whose CBAM amendments entered into force on 20 October 2025.[⁵] The key point: a new threshold of 50 tonnes per year in net weight.

Importers bringing in less than 50 tonnes per year of the four affected product categories (iron/steel, aluminium, cement, and fertilisers) are exempt from CBAM obligations – no threshold applies for electricity and hydrogen. This means they do not need to apply to become an authorised CBAM declarant, do not need to pay for certificates, and do not need to submit a CBAM report.[⁶]

According to the European Commission's own calculations, the threshold means that approximately 90 per cent of all importers – mainly SMEs – are exempt from CBAM obligations. At the same time, the remaining 10 per cent still cover 99 per cent of the relevant emissions.[⁷]

Key details about the threshold:

• The 50-tonne limit applies to your total import of CBAM goods across the entire EU, not per shipment

• The limit does not apply to electricity and hydrogen – importers of these must hold authorised declarant status regardless of volume[⁸]

• You must monitor yourself whether your import volume is approaching the threshold – no automatic warning system exists

What will it cost in practice?

The cost is calculated on the embedded emissions in what you import – not on the weight or value of the goods. Three factors determine the final bill:

Country of production matters significantly. Goods from countries with strong carbon pricing systems can attract a deduction for the price already paid in the country of origin. Goods from countries without carbon pricing receive no deduction – those importers will pay more.

The CBAM factor is phased in gradually. In parallel with the phasing out of free EU ETS allowances (2026–2034), the proportion of emissions that must be covered by certificates increases. During 2026, it is therefore not 100 per cent of embedded emissions that need to be covered – that proportion rises progressively through to 2034.[³]

Actual emissions data yields a lower cost. If your supplier can provide verified emissions data, this may result in a lower CBAM cost than EU default values, which tend to be set high. It pays to request emissions data early.

What do you need to do if you are affected?

Step 1: Find out whether you import CBAM goods Go through your import list and identify goods that fall under the six sectors. Check the customs codes for each product – the Swedish Customs Authority (Tullverket) and the Swedish Environmental Protection Agency (Naturvårdsverket) publish lists of which CN codes are covered.[⁹]

Step 2: Assess your volume against the 50-tonne threshold Are you importing more or less than 50 tonnes per year in total of CBAM goods? If you are close to the threshold, calculate carefully and have a plan for if volumes increase.

Step 3: Apply for authorised CBAM declarant status if you exceed the threshold Swedish importers apply through Tullverket's e-services, and it is Naturvårdsverket that reviews and decides. If you lack declarant status when attempting to import CBAM goods above the threshold, the goods will be refused entry into the country.[⁹]

Step 4: Secure emissions data from your suppliers Ask your suppliers outside the EU for product-specific emissions data. Without it, you fall back on EU default values, which can be more expensive. It is also a way to have accurate figures on hand if customers or financiers ask.

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Frequently asked questions about CBAM

Does CBAM affect my company if I don't work in the steel or cement industry?

Not directly – CBAM affects you as an importer of the six product categories, not as a company operating within those sectors. A consultancy or trading company in Sweden that imports aluminium components from China is affected by CBAM. A Swedish steel manufacturer is not affected by CBAM (they pay instead through EU ETS). What matters is what you buy in and where it comes from.

What happens if I don't apply for CBAM declarant status but still import more than 50 tonnes?

Tullverket checks from 1 January 2026 whether the importer holds authorised CBAM declarant status. Without it, import of the affected goods is not permitted. There is a transitional arrangement: if you have applied for status before 31 March 2026, you can enter the application number in the customs declaration while awaiting a decision.[⁹]

What are "embedded emissions"?

The greenhouse gas emissions arising from the production of a good in the country of manufacture – the carbon "embedded" in the product, not the emissions from transport. For simple goods such as steel bar, it is the emissions from the manufacturing process. For complex goods with multiple input materials, the emissions from the components are added together.

What does it mean that the certificate price is linked to EU ETS?

The price reflects the EU market for emission allowances and varies with supply and demand. For Q1 2026 the price was set at €75.36 per tonne of CO₂e.[⁴] The cost is therefore not fixed – it is updated quarterly during 2026 and weekly from 2027.

Can I deduct costs if the supplier has already paid carbon tax in their country?

Yes. If your supplier can demonstrate that a carbon price has already been paid in the country of origin, this is deducted from the CBAM cost. This is a reason to have a dialogue with suppliers about their climate charges and emissions data.

Does the 50-tonne threshold apply per shipment or in total per year?

In total per year, across all your imports of CBAM goods to the entire EU combined. Note that the threshold does not apply to electricity and hydrogen.[⁸]