CLITE
HERE THE OBLIGATION IS CALCULATED

CBAM

The Carbon Border Adjustment Mechanism entered its definitive phase in January 2026. Importers of covered goods need authorised declarant status. Certificate sales open 1 February 2027. The first annual declaration and certificate surrender are due by 30 September 2027, for 2026 imports.

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Goods crossing a carbon border, drawn in tapestry styleWorkers feed a smoking furnace at left. A ship carries metal bars across the sea. At right an official at a border gate weighs the cargo and records it on a scroll.
WHAT CHANGED IN 2026

Reporting became payment

A financial obligation

The transitional phase asked for reports. The definitive phase asks for certificates surrendered against a declaration, with penalties behind it.

The cost climbs to 2034

A phase-in factor limits the obligation in the early years and rises each reporting year. Planning on the 2026 number understates what is coming.

The small-consignment exit closed

The 150 euro per consignment derogation was repealed by Reg (EU) 2025/2083 and replaced with a single mass-based threshold.

WHAT IS COVERED

Scope and the threshold

Once cumulative net mass passes 50 tonnes per importer per calendar year, the full annual volume is obligated, not the excess.

GOODS
THRESHOLD
NOTE
Iron and steel
50 t threshold applies

Direct emissions only (most CN codes)

Aluminium
50 t threshold applies

Direct emissions only

Fertilisers
50 t threshold applies

Direct and indirect emissions

Cement
50 t threshold applies

Direct and indirect emissions

Electricity
No mass threshold

Outside Art. 2a, obligated from the first unit

Hydrogen
No mass threshold

Outside Art. 2a, obligated from the first unit

The threshold sits in Art. 2a of Regulation (EU) 2023/956 as amended. The military-use exclusion under Art. 2(3) remains in force.

HOW THE WORK RUNS

The seven-step workflow

I

Set up the declarant

Authorised declarant, EORI, reporting year and installations of origin.

II

Load the imports

Goods, CN codes, net mass and country of origin for the year.

III

Attach supplier data

Actual verified emissions from the installation, with the verifier's report.

IV

Run the obligation

Deterministic engine, twelve steps, each recorded.

V

Deduct carbon price paid

Carbon price already settled at origin, where it is evidenced.

VI

Review the position

Certificate count, phase-in factor and the basis for every figure.

VII

Export the declaration

XML for the declarant to file, with the supporting pack.

THE DETERMINISTIC ENGINE

What the engine establishes

The engine takes no view and makes no estimate. Every figure it produces can be traced back to an input and an article.

The calculation

  • Whether the importer crosses the mass threshold for the calendar year
  • Embedded direct emissions for each good, from the installation's data
  • Embedded indirect emissions where the goods group requires them
  • The emissions basis for each line: actual verified today, default route in build
  • The phase-in factor for the reporting year
  • The carbon price paid at origin, deducted where evidenced
  • The certificate count to surrender

The record

  • Inputs held with their source and the date they were supplied
  • Method named for each step, not implied
  • Regulatory values loaded from the instrument, never inferred
  • Recalculation reproducible and versioned
  • Carbon price deduction evidenced or absent, never assumed
  • Trail retained for audit by default
THE PRICE MOVES

Certificates

The certificate price tracks the EU carbon price. For 2026 imports it is set quarterly. From 2027 it is set weekly. A year's exposure is therefore not fixed at the moment of import.
An importer who prices CBAM once, at the start of the year, is carrying EU ETS volatility without knowing it.

Clite reports the position as it stands. It does not forecast the carbon price.

WHAT IT RESTS ON

Regulations covered

REGULATION (EU) 2023/956
The mechanism itself.
REGULATION (EU) 2025/2083
Omnibus amendment, including the mass threshold.
IR 2025/2546
Verification of embedded emissions.
IR 2025/2547
Calculation methodology.
IR 2025/2548
Price of CBAM certificates.
IR 2025/2620
Free allocation adjustment and CBAM benchmarks.
IR 2025/2621, AS CORRECTED BY IR 2026/1740
Default values and mark-up. Route in build.
WHO DOES WHAT

Operating model

Stated plainly, because the division of labour is where CBAM projects go wrong.

SUPPLIER CONTACT
The importer approaches the supplier. Clite works from the documents the supplier furnishes.
SITE VISITS
None. Clite provides technology services only.
FILING
Clite produces the declaration XML. The declarant submits it.
REGISTRY
Integration is out of scope.
DATA RETENTION
Audit trail kept by default, deleted only if you opt out.
HOSTING
AWS eu-west-1 (Ireland).
WHAT IT DOES NOT DO YET

Known limits

Published here rather than discovered in a sales call.

Default values

The default values under IR 2025/2621, as corrected by IR 2026/1740, are not yet loaded. The default route and its mark-up are in build.

Schema validation

The official EU XSD has not been released. Output XML is produced for the declarant's workflow but cannot yet be validated against the published schema.

Supplier onboarding

Bringing a non-EU supplier to verified-data readiness is on the roadmap. Today the platform serves suppliers already reporting actual verified emissions.

BEFORE YOU START

Onboarding checklist

Declarant status

Confirm authorised CBAM declarant status and the EORI the imports sit under.

Goods and volume

List goods, CN codes and expected annual net mass, so the threshold test can be run early.

Installations

Identify the installation of origin behind each good and the operator who runs it.

Verified emissions

Request actual verified emissions and the accredited verifier's report from each installation.

Carbon price paid

Gather evidence of any carbon price already settled at origin. Without evidence there is no deduction.

Review and file

Load the year, review the position line by line, export the declaration and submit it.

WHAT IS COMING

On the horizon

UK CBAM

A second jurisdiction, from 1 January 2027, will be handled as a parameter set on the same module rather than a separate build.

Downstream goods

The proposed 2028 extension to downstream goods is the largest change on the horizon. The module is architected for it.

CBAM is the first of five mandates on a single base. See the full ledger.

POSITION IS VERIFIED HERE

Join the waitlist

Tell us what you import and where it comes from.
We will come back with what Clite covers today, and what it does not.

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