CBAM Exposure & Cost Estimator
CBAM's definitive, financially binding phase started 1 January 2026. The EU importer is the one who registers, reports and pays — not the supplier — but the importer's declaration runs on data that only the supplier has: production route, embedded emissions, mill certificates. Stainless washers sit under CN 7318, which is listed in CBAM Annex I, so EU imports have carried CBAM certificate obligations since 1 January 2026. From 2026 only direct emissions count, and imports below the 50-tonne annual net-mass threshold stay outside CBAM. This tool runs the numbers both sides need in order to budget. For 2026 imports the realistic basis is the Commission's default value, so the calculator can fill in the official China defaults for washers.
Two other tools that pair with this one: the full CBAM explainer for washer importers covers the regulation in detail, and the weight calculator gets you a net-weight figure if you only know dimensions and quantity, not kilograms.
Part 1 — De-minimis exposure check
The 50-tonne threshold decides whether CBAM applies to you at all. It's assessed across all your CBAM-covered imports for the year, not just washers.
Note: hydrogen and electricity imports are excluded from this de-minimis calculation entirely — they're covered separately. The 50-tonne threshold itself is a policy setting (introduced via the Omnibus simplification package) and may be reviewed or adjusted; don't treat it as permanent.
Part 2 — Indicative CBAM certificate cost
This follows the calculation the EU actually prescribes, rather than a flat emissions × price multiplication. The benchmark deduction and the CBAM factor both reduce what is payable, and leaving them out overstates the cost substantially.
Official cost formula (per tonne of imported goods):
[ specific CO2 emissions − ( benchmark × CBAM factor ) ] × certificate price − carbon price already paid in the country of origin
Source: Implementing Regulation (EU) 2025/2620. The regulation also multiplies the benchmark by a cross-sectoral correction factor (CSCF) that the Commission publishes; this tool uses 1.
Indicative budgeting figure only — not a declaration figure. The declared amount must come from the producer’s verified installation-level data, or from the Commission’s official default value for the exact 8-digit CN code and country of origin. The European Fastener Distributor Association (EFDA) considers it highly unlikely that verified actual data can be used for 2026 imports, so most importers will declare default values for 2026. From 2026 only direct emissions count for iron and steel. This is not legal, tax or customs advice.
Worked example: washers from China, 2026
One tonne of flat washers (CN 7318 22 00), made and imported in 2026, declared on the default value, at the Q2 2026 certificate price of €75.28:
(5.011 − 1.364 × 0.975) × €75.28 = 3.681 × €75.28 ≈ €277 per tonne
Spring and lock washers (CN 7318 21 00): (3.012 − 1.330) × €75.28 ≈ €127 per tonne. At the same certificate price the flat-washer figure rises to about €314 per tonne for 2027 and €353 for 2028, because the mark-up goes up and the CBAM factor goes down. The certificate price itself will also move.
Per piece: a stainless DIN 125 M8 washer weighs about 1.85 g, so €277 per tonne works out to roughly €0.51 per 1,000 washers; an M12 (6.34 g) comes to about €1.76 per 1,000. Piece weights for other sizes are in our washer weight calculator.
Reference values used above
| CN code | Goods | Published | 2026 (+10%) | 2027 (+20%) | 2028 on (+30%) |
|---|---|---|---|---|---|
| 7318 22 00 | Washers: flat, fender, square-hole | 4.555 | 5.011 | 5.466 | 5.922 |
| 7318 21 00 | Spring washers and other lock washers | 2.738 | 3.012 | 3.286 | 3.559 |
| Year | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 | 2032 | 2033 | 2034 |
|---|---|---|---|---|---|---|---|---|---|
| CBAM factor | 0.975 | 0.950 | 0.900 | 0.775 | 0.515 | 0.390 | 0.265 | 0.140 | 0.00 |
| Route / step | Benchmark (tCO2e / t) | When it applies |
|---|---|---|
| Route (C): carbon steel via blast furnace and basic oxygen furnace | 1.364 | With default values where the default names route (C). Both Chinese washer defaults do. |
| Route (D): carbon steel via direct-reduced iron and electric arc furnace | 0.475 | With default values where the default names route (D). |
| Route (E): carbon steel from scrap in an electric arc furnace | 0.066 | With default values where the default names route (E). |
| Washer-making step, with actual data | 0.038 | With verified actual data, added to the benchmarks of each precursor (the coil and the steel before it), not used on its own. |
| Year | 2026 | 2027 | 2028 onwards |
|---|---|---|---|
| Mark-up, iron and steel | +10% | +20% | +30% |
Default or actual data? For 2026 imports, default values are the realistic basis. From 2027 an importer can use the producer’s verified actual figure instead, but for stainless washers it is not automatically lower. The actual figure is built from the coil’s embedded emissions, including the ferro-nickel and ferro-chrome that go into stainless steel, multiplied by the coil used per tonne of washers including punching scrap. Depending on the mill, that can land above or below the washer default, so compare the two before paying for verification.
Part 3 — What your EU buyer will ask you for
If you supply an EU importer of washers, this is the practical list — the documents and data points that come up once they start their CBAM declaration or vendor-qualification process.
- 1CN code and net mass per shipment: 7318 22 00 for flat, fender and square-hole washers, 7318 21 00 for spring and lock washers, in kilograms on the commercial documents.
- 2Country of origin and production dates: the dates decide which year’s mark-up applies to goods made before the year they are imported.
- 3Mill test certificate with chemistry: EN 10204 3.1, tracing the coil to a specific melt, with the grade, the Cr and Ni content and the country where the coil was made.
- 4Coil used per tonne of washers: including punching scrap. Only needed if the importer wants to use actual data.
- 5Verified installation-level emissions: for iron and steel only direct emissions count. In practice this data has to come from the coil mill and be checked by an accredited verifier; the washer stamping step itself is outside the CBAM system boundary.
- 6Operator registration in the CBAM Registry: voluntary for producers outside the EU (Article 10 of Regulation (EU) 2023/956). It lets verified data be shared with the importer’s declaration directly.
- 7Carbon price paid at origin: deductible only if it was genuinely paid and can be evidenced. For goods from China it is effectively zero at present.
What HUIHUI provides: the CN code and net weight on every shipping document, production dates, the grade checked with our own handheld XRF spectrometer, and coil-consumption figures on request. Our stamping step sits outside the CBAM system boundary, so the number that matters is the coil mill’s. We cannot obtain the mill’s certificate or emissions data, so for our washers declare on the Commission’s default value, which is what the calculator above fills in.
Key dates for EU importers
| Date | What happens |
|---|---|
| 1 January 2026 | Definitive period starts. Importing CBAM goods above 50 t a year requires authorised-declarant status. |
| Early October 2026 | The Commission publishes the Q3 2026 certificate price; Q4 follows in early January 2027. |
| 1 February 2027 | Sale of CBAM certificates starts on the common central platform. |
| End of each quarter from 2027 | Declarants must hold certificates covering at least 50% of the embedded emissions of that year’s imports so far. |
| 30 September 2027 | First annual CBAM declaration and surrender of certificates, for goods imported in 2026. |
| 1 January 2028 (proposed) | Possible extension of CBAM to downstream steel and aluminium products. Washers are already covered; the extension would matter for importers of products that contain them. Still being negotiated between Parliament and Council. |
Failing to surrender enough certificates carries a penalty of €100 per tonne of CO2e, indexed to inflation, and the missing certificates still have to be surrendered.
FAQ
Are washers already covered by CBAM?
Yes. Washers fall under CN 7318, which is listed in Annex I to Regulation (EU) 2023/956, so importers need CBAM certificates for the embedded emissions of washers imported from 1 January 2026. Flat, fender and square-hole washers are 7318 22 00; spring and lock washers are 7318 21 00. Separately, the Commission proposed in December 2025 to extend CBAM to downstream products from 2028; the Council agreed its position on 12 June 2026 and the European Parliament on 15 September 2026, and the final text is still being negotiated. That extension concerns products that contain steel, not washers themselves. From 2026 only direct emissions count for iron and steel, and importers below 50 t a year stay outside CBAM.
How much does CBAM add per washer?
On the 2026 default value and the Q2 2026 certificate price of €75.28, flat washers carry about €277 per tonne. A stainless DIN 125 M8 washer weighs about 1.85 g, so that is roughly €0.51 per 1,000 pieces; an M12 (6.34 g) is about €1.76 per 1,000. Importers below 50 t of covered goods a year pay nothing. The figure rises in 2027 and 2028 as the default-value mark-up goes up.
Who pays, importer or supplier?
The EU importer. They register as the authorised CBAM declarant, file the annual declaration, and buy and surrender the CBAM certificates. The non-EU manufacturer, such as HUIHUI, has no CBAM payment obligation. But the importer's declaration runs on embedded-emissions data that has to come from the manufacturer, so the supplier still carries a practical data-sharing role even without a financial one.
What does CBAM add per tonne of washers from China?
On the official default values and the Q2 2026 price of €75.28, about €277 per tonne for flat washers (7318 22 00) and about €127 per tonne for spring and lock washers (7318 21 00) imported in 2026. The calculation is (default value with the 10% mark-up minus 1.364 × 0.975) × certificate price. At the same price the flat-washer figure is about €314 for 2027 and €353 for 2028.
What is the CBAM certificate price now?
€75.36 per tCO2e for Q1 2026 and €75.28 for Q2 2026. The Q3 2026 price is expected in early October 2026. Through 2026 the price is the average of EU ETS auction prices in each quarter; from 2027 it is published weekly. Certificates for 2026 imports can be bought from 1 February 2027.
Is the default value different for stainless washers?
No. The washer codes 7318 21 00 and 7318 22 00 have one default value per country, whatever the grade, and both Chinese defaults are calculated on route (C), carbon steel via blast furnace. Stainless steel made with ferro-nickel and ferro-chrome can carry more embedded emissions than that, so a stainless washer's verified actual figure is not guaranteed to be lower than the default.
How do I lower my CBAM cost?
For 2026 imports the levers are limited: stay below 50 t a year if that is realistic for you, and keep the production dates of each lot, because goods made before the year of import can use that earlier year's lower mark-up. From 2027, verified actual data can replace the default, but compare first, especially for stainless. The benchmark deduction is applied in the declaration. A carbon price paid in the country of origin reduces the bill only if it was genuinely paid and can be evidenced; for goods from China that is effectively zero at present.
What data can HUIHUI provide?
The CN code and net weight on every shipping document, production dates, the grade checked with our own handheld XRF spectrometer, and coil-consumption figures on request. Our stamping step sits outside the CBAM system boundary, so the number that matters is the coil mill's. We cannot obtain the mill's certificate or emissions data, so for our washers declare on the Commission's default value, which is what the calculator above fills in.
Disclaimer: This tool is general background information for procurement and trade professionals, not legal, customs, or regulatory advice. CBAM rules, implementing regulations, certificate prices, and the list of covered goods (Annex I) change over time, and the figures used here (de-minimis threshold, benchmark emission factors, certificate price) are current as of the update date shown above and may be out of date by the time you read this. Confirm current requirements and figures with a qualified customs adviser, CBAM consultant, or your national competent authority before making a compliance or budget decision.
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