EUDR and CBAM cover different goods. The EU Deforestation Regulation (EUDR) requires due diligence on seven deforestation-linked commodities, such as coffee, cocoa and wood, before they are placed on the EU market or exported. CBAM, the carbon border adjustment mechanism, prices the emissions in imported steel, aluminium, cement, fertilisers, hydrogen and electricity through certificates and an annual declaration.
How do they compare side by side?
| EUDR | CBAM | |
|---|---|---|
| Aim | Cut the EU’s contribution to deforestation and forest degradation | Price the emissions in imports, to prevent carbon leakage |
| Goods | Cattle, cocoa, coffee, oil palm, rubber, soya and wood, and products made from them | Cement, electricity, fertilisers, iron and steel, aluminium, hydrogen |
| Who files | The operator that places the goods on the market or exports them | An authorised CBAM declarant, needed to import CBAM goods above the 50-tonne exemption |
| What is filed | A due diligence statement before goods are placed or exported; one can cover several shipments | One annual declaration, by 30 September for the year before |
| Money | No fee or certificate; the money risk is penalties | Certificates bought and surrendered for the embedded emissions |
| Quantity threshold | None | Importers of 50 tonnes or less of CBAM goods a year are exempt, except for electricity and hydrogen |
| Direction | Imports and exports | Imports |
The two rules share no product sectors, so one shipment rarely falls under both. A company that imports both kinds of goods runs two separate processes.
Example: aluminium and coffee in the same year
Example. In 2027 an EU importer brings in 40 tonnes of aluminium and 40 tonnes of green coffee. For CBAM, 40 tonnes is under the 50-tonne threshold, so the importer is exempt that year. For EUDR, the coffee needs a due diligence statement whatever the quantity.
When does each one bite?
CBAM’s definitive phase started on 1 January 2026, with the first declaration and surrender of certificates due by 30 September 2027. The EUDR dates are in whether EUDR has been delayed. The CBAM side is covered in what CBAM is and how CBAM certificates work.
Where this comes from: Regulation (EU) 2023/1115, Articles 1, 4 and 25; Regulation (EU) 2023/956, Articles 1, 2a, 4, 6 and 22, as amended by Regulation (EU) 2025/2083.
More on this: EUDR guide · EUDR compliance
Reviewed by Team GreenSutra on 26 October 2026.