Likely*
Only if the actual CN codes are covered and the relevant importer crosses the annual threshold.
India → Germany · Iron and steel · CBAM definitive regime
See the screening before you buy the full compliance work.
This fictional case shows how Viridis turns a broad regulatory question into a bounded decision sheet: what likely applies, which party acts, what evidence is missing, and what should happen in the next 30 days.
Screening support, not legal or customs advice. The example states its assumptions and refuses to infer product classification, legal scope, or emissions values from incomplete facts.
The fictional buyer question
“We make steel components in India and sell them to a German customer. What must be ready for CBAM in 2026?”
Viridis narrows that question into facts a trade, sustainability, or legal advisor can validate quickly.
- ProducerPune-based steel component manufacturer
- EU counterpartyGerman importer of record
- Illustrative volume120 tonnes during 2026
- Goods assumptionCovered iron or steel CN codes
- Evidence postureNo verified embedded-emissions file supplied yet
Executive result
Likely in scope under the stated assumptions—four facts still control the real answer.
EU side
The EU importer or indirect customs representative—not the Indian producer—holds the declarant obligation.
30 Sep 2027
The first declaration and certificate surrender, due 30 September 2027, covers qualifying 2026 imports.
Evidence
Supply installation and product emissions information that the importer can use and verify.
*This is an illustrative applicability screen, not a legal determination.
Decision sheet
What the team should decide next
| Priority | Decision | Current screen | Evidence or action required |
|---|---|---|---|
| 1 | Are the goods covered? | Assumed yes for this example. | Validate every Combined Nomenclature code with the importer and a qualified customs adviser. |
| 2 | Does the threshold apply? | 120 tonnes suggests the mass threshold may be crossed. | Confirm the relevant importer's total annual covered-goods mass; do not use one supplier's shipment volume as the legal test. |
| 3 | Can the importer clear customs? | Not proven. | Obtain the importer's CBAM account number or permitted application reference and confirm the responsible declarant. |
| 4 | Can actual emissions be used? | No verified file supplied. | Map the installation, production route, direct and indirect emissions data, methodology, and verifier readiness. Consider the non-EU operator registry workflow. |
| 5 | What is the financial exposure? | Indeterminate from tonnage alone. | Combine verified embedded emissions, applicable adjustments and deductions, import timing, and the Commission's certificate-price schedule. |
Key dates and price signal
1 Jan 2026
Definitive regime
The Commission distinguishes the definitive registry from the 2023–2025 transitional registry.
Feb 2027
Certificate purchases
Purchases on the common central platform begin in February 2027.
€75.28
Q2 2026 reference
The published quarterly certificate-price reference is useful for planning, but it is not this company's liability.
30 Sep 2027
First declaration
The first declaration and corresponding certificate surrender covers 2026 imports.
30-day action plan
Move from “CBAM applies” to an evidence-ready importer handoff.
- Classify the goods.
Create a product-to-CN-code table and have the importer or customs adviser validate it. - Resolve the responsible party.
Name the EU importer or indirect customs representative and capture its account number or application reference. - Build the emissions data room.
Document the installation, production route, activity data, electricity treatment, allocation method, and evidence owners. - Choose actual values or model the fallback.
Assess whether verified actual emissions can be delivered in time and what the commercial consequence is if they cannot. - Assign a 2027 filing calendar.
Work backward from certificate purchasing and the 30 September declaration-and-surrender date.
What Viridis refuses to guess
No false precision. This input cannot establish the legal CN classification, whether the importer's aggregate volume crosses the threshold, whether its declarant application is valid, the producer's verified embedded emissions, or the final certificate quantity and cost. Those are explicit follow-up facts, not invented answers.
Primary sources
European Commission — CBAM communication and FAQs
50-tonne signal, account or application-reference requirement, and the first declaration date.
European Commission — CBAM Registry and Reporting
Definitive and transitional registry periods, authorisation workflow, and non-EU installation operator module.
European Commission — Price of CBAM certificates
2026 quarterly price methodology, published prices, and February 2027 purchasing start.
Sources were checked for this illustrative preview on 24 July 2026 and are checked again for each delivered snapshot.
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