Poland ranks among the EU's largest importers of carbon-intensive steel, sourcing significant volumes from Ukraine and Russia, two of the most coal-dependent steel-producing nations supplying the European market. Polish companies importing these goods now face direct financial and legal obligations under Regulation (EU) 2023/956, the definitive phase of which began on January 1, 2026. The authorization deadline passed on March 31, 2026, and the first CBAM declaration covering calendar year 2026 imports falls due on September 30, 2027. Understanding how KOBiZE administers authorization and what Polish importers must document at every step determines whether a business carries unnecessary risk or meets every deadline cleanly.
Caption: Poland's coal-heavy industrial base makes the country one of the EU's most exposed member states for steel import compliance under CBAM.
What CBAM Means for Polish Steel Importers in 2026
CBAM is a certificate-based mechanism under Regulation (EU) 2023/956 that requires EU importers of carbon-intensive goods to purchase CBAM certificates proportional to the verified embedded CO₂ emissions in their imports, priced at the EU ETS auction rate, to prevent carbon leakage from the EU Emissions Trading System. Polish companies importing steel, cement, aluminium, fertilizers, electricity, or hydrogen from outside the EU and the European Economic Area must comply with this regulation from January 1, 2026 onward.
Poland's exposure is concentrated in steel. Ukrainian blast furnace and basic oxygen furnace (BF-BOF) steel carries an emission factor of approximately 2.0 tCO₂ per tonne of product. At the current EU ETS price of approximately €70 per tonne of CO₂ (as of late March 2026), the gross CBAM cost for BF-BOF steel reaches approximately €140 per tonne. The net financial obligation in 2026 is much lower, because only 2.5% of free allocation has been reduced (the CBAM factor for 2026 under Article 10a(1a) of Directive 2003/87/EC as amended), bringing the net cost to approximately €3.50 per tonne of BF-BOF steel imported in 2026. The net obligation escalates sharply from 2028 onward as free allocation phases out.
The EU CBAM framework applies identically to Polish importers as it does to all other EU member state operators, but the specific authority responsible for authorization, declarations, and enforcement in Poland is KOBiZE, the National Centre for Emissions Management (Krajowy Ośrodek Bilansowania i Zarządzania Emisjami), operating under the Chief Inspectorate for Environmental Protection.
KOBiZE: Poland's CBAM Competent Authority
KOBiZE serves as Poland's National Competent Authority (NCA) for CBAM, receiving authorization applications, managing Polish declarant accounts in the EU CBAM Registry, selling CBAM certificates from February 1, 2027 via the Common Central Platform, conducting risk-based inspections, and issuing financial penalties for non-compliance.
KOBiZE was already the established administrator of Poland's participation in the EU Emissions Trading System before CBAM entered force. This prior ETS experience means the agency operates the same UUM&DS authentication infrastructure that Polish declarants use to access the CBAM Registry, making the registry access process familiar to companies already operating under EU ETS. Polish companies without any prior ETS experience must register new UUM&DS credentials through the EU Customs Trader Portal before they can file authorization applications or access their CBAM account.
The authorization deadline of March 31, 2026 applied to all Polish importers wishing to continue importing CBAM goods under the provisional import provision in Article 17(7a) of Regulation (EU) 2023/956, as inserted by Regulation (EU) 2025/2083. Importers who submitted applications by that date may continue importing while KOBiZE processes their applications, which must be completed within 120 days from receipt of a complete application. Importers who missed the March 31, 2026 deadline and continue to import CBAM goods face penalties of €300 to €500 per tonne of CO₂e (3 to 5 times the standard certificate rate), enforceable by KOBiZE under Article 26(2) of the regulation.
Poland's Steel Import Profile and CBAM Exposure
Poland's position as a major steel importer derives from its construction sector, manufacturing base, and geographic proximity to Ukraine. The dominant source countries for Polish steel imports create specific CBAM compliance challenges, because neither Ukraine nor Russia operates a qualifying carbon pricing scheme that would allow Polish importers to claim an Article 9 deduction against their CBAM certificate obligation.
The principal origin countries creating Polish CBAM exposure for steel are outlined in the table below.
| Origin Country | Production Route | Approximate Emission Factor | Carbon Pricing | Article 9 Deduction Available |
|---|---|---|---|---|
| Ukraine | BF-BOF (blast furnace) | ~2.0 tCO₂/t | None (ETS under development) | No |
| Russia | BF-BOF and EAF mixed | ~1.8–2.0 tCO₂/t | None effective | No |
| South Korea | EAF and BF-BOF | ~0.5–2.0 tCO₂/t | K-ETS (pending Commission assessment) | Pending |
| Turkey | BF-BOF and EAF | ~1.5–2.0 tCO₂/t | Pilot ETS (full free allocation in 2026) | No (2026) |
Emission factors are product-specific approximations based on Regulation (EU) 2023/956 Annex I reference values. Gross CBAM cost at €70/tCO₂ ETS price: BF-BOF steel €140/t. Net 2026 cost after CBAM factor: approximately €3.50/t.
For Polish importers sourcing from Ukraine, the absence of a qualifying Ukrainian carbon pricing scheme means no Article 9 deduction reduces certificate obligations. Ukraine is developing an ETS as part of its EU accession process, but Commission recognition of that scheme as qualifying under Article 9 remains years away. Polish importers sourcing from Russia face the same position, with additional complications from EU sanctions that have significantly reduced Russian steel trade flows since 2022. The steel sector under CBAM analysis covers how BF-BOF and EAF production routes determine embedded emission calculations across origin countries.
The Authorization Process with KOBiZE
Polish importers obtain authorized CBAM declarant status by submitting a complete application through the Authorization Management Module (AMM) of the EU CBAM Registry at cbam.ec.europa.eu. KOBiZE receives and assesses these applications as Poland's NCA.
The documents required under Implementing Regulation (EU) 2025/486 (Articles 4 to 8) include the following items, which Polish applicants must prepare before submission.
- A valid EORI number registered with the Polish customs authority (Krajowa Administracja Skarbowa)
- Polish business registration documentation (KRS entry or CEIDG entry for sole traders)
- Polish tax identification number (NIP)
- Audited financial statements for the preceding 2 to 3 years, or a bank guarantee if the entity was established less than 2 years ago
- Evidence of 5-year customs and tax compliance history: no serious customs violations, no convictions for tax fraud, smuggling, money laundering, or environmental offenses, no active insolvency proceedings
- A description of CBAM goods to be imported, including CN codes from Chapters 72 and 73 of the Combined Nomenclature for steel products, estimated annual tonnage per product type, countries of origin, and production installation names and addresses with geographic coordinates
- Identification of the natural person within the company legally responsible for CBAM compliance and declaration accuracy
- An internal CBAM compliance procedures document
KOBiZE assesses each application within a maximum of 120 days from receipt of a complete submission. The 120-day clock pauses if KOBiZE requests additional information. Grounds for refusal under Article 17 of the regulation include serious customs violations in the prior 5 years, criminal convictions for relevant offenses, active EU financial sanctions, and active insolvency proceedings.
Polish companies that are authorized CBAM declarants must understand the full scope of EU importer obligations that arise after authorization, including embedded emissions data collection, verifier engagement, certificate purchase, and annual declaration filing.
Embedded Emissions Data: The Operational Challenge for Polish Importers
Embedded emissions data collection represents the highest-complexity compliance task for Polish steel importers sourcing from Ukraine. The importer must obtain, from each non-EU production installation supplying their goods, the specific direct embedded emissions expressed in tonnes of CO₂e per tonne of product, the production route classification applied, a reference to the monitoring plan at that installation, and supporting measurement data.
Ukrainian steel producers, particularly those operating blast furnaces in the Zaporizhzhia and Dnipro regions, face significant operational disruptions from the ongoing armed conflict. Monitoring infrastructure at some installations has been damaged or destroyed, making verified actual emissions data impossible to obtain for certain production flows. Polish importers sourcing from conflict-affected Ukrainian installations face a documented inability to obtain verified actual data, which pushes them toward default values published by the Commission in Implementing Regulation (EU) 2025/2621.
Default values carry increasing financial penalties over time. The mark-up schedule applies as follows: 10% above the calculated default in 2026, 20% above the default in 2027, and 30% above the default from 2028 onward. For steel, default values are set at the average emission intensity for the country of origin. Using default values also eliminates the need for third-party verification, since verification under Article 8 of the regulation applies only to actual values, not defaults. This creates a pragmatic short-term option for Polish importers dealing with disrupted Ukrainian supply chains, at the cost of greater financial exposure as the mark-up schedule increases after 2027.
Where Ukrainian or Russian producers can provide actual emissions data, Polish importers must engage an accredited verifier to verify that data. Verifiers must be accredited under EN ISO/IEC 14065 by a National Accreditation Body recognized by European Accreditation (EA). For the first verification period covering 2026 imports, a physical site visit to the non-EU production installation is mandatory under Delegated Regulation (EU) 2025/2551. Remote verification is not permitted for initial assessments. Verifier registration in the CBAM Registry opens September 1, 2026, giving verifiers a 13-month window before the September 30, 2027 declaration deadline. Verification fees range from €5,000 to €50,000 per installation, depending on complexity. Polish importers sourcing from 10 or more separate installations face total first-cycle verification costs that can reach €500,000 or more.
Caption: The net CBAM certificate cost in 2026 remains low due to the 2.5% CBAM factor, but the obligation structure grows substantially from 2028 onward.
CBAM Certificate Obligations and the Annual Declaration
Polish importers approaching their first CBAM declaration deadline on September 30, 2027 must complete a sequence of steps between now and that date. The declaration covers all CBAM goods imported during calendar year 2026 and must be filed via the CBAM Registry with KOBiZE as the receiving NCA.
CBAM certificates become available for purchase on February 1, 2027, via KOBiZE through the Common Central Platform. The price for certificates covering 2026 imports is set at the quarterly average of EU ETS auction closing prices during each quarter of the 2026 import year (Article 22(1a), inserted by Regulation (EU) 2025/2083). This means Polish declarants will know the 2026 certificate price before they make their first purchases in early 2027. From 2027 imports onward, the price shifts to the weekly average of EU ETS auction closing prices under Article 22(1).
The quarterly holding requirement applies from 2027 onward. At the end of each calendar quarter, Polish authorized declarants must hold CBAM certificates equal to at least 50% of the cumulative embedded emissions of all CBAM goods imported since the start of that calendar year, adjusted for the SEFA free allocation factor. KOBiZE issues formal notices to declarants that fall short of this threshold.
The annual CBAM declaration under Article 6 of the regulation must contain the following content items.
- Total quantity of CBAM goods imported in the calendar year, broken down by goods type and country of origin, expressed in tonnes
- Total specific embedded emissions per goods type and country of origin, expressed in tCO₂e per tonne
- Total number of CBAM certificates to be surrendered after all deductions
- Article 9 deduction claims for carbon prices effectively paid in the country of origin, supported by documentation
- Verification report references for all actual values used
- The SEFA free allocation adjustment calculation
Certificate surrender occurs at the time of declaration filing. KOBiZE cancels the surrendered certificates in the registry immediately upon receipt.
What Happens If Polish Importers Do Not Comply
Non-compliance with CBAM in Poland generates two categories of financial penalty, both administered by KOBiZE under Article 26 of Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083.
Authorized declarants who fail to surrender sufficient certificates at the declaration deadline face a penalty of €100 per tonne of CO₂e not covered. This penalty does not eliminate the surrender obligation. The declarant must still procure and surrender the missing certificates at market price (approximately €70/tCO₂ as of late March 2026) in addition to the €100 penalty, bringing the total cost of non-compliance to approximately €170 per tonne CO₂e minimum.
Unauthorized persons who import CBAM goods without holding authorized declarant status face penalties of €300 to €500 per tonne of CO₂e, representing 3 to 5 times the standard certificate rate. KOBiZE can also flag such importers to customs authorities, who implement real-time authorization validation at the Polish border from January 1, 2026 onward. Goods entering Poland from non-EEA origins under CN codes listed in Annex I of the regulation are automatically flagged for CBAM authorization status verification before release into free circulation.
Compliance Planning for Polish Importers in 2026 and Beyond
Polish companies managing CBAM obligations across multiple steel import flows need a structured approach covering authorization, data collection, verifier procurement, and certificate purchase planning. The effective CBAM cost per tonne of BF-BOF steel rises substantially over the next decade. At the current ETS price of approximately €70/tCO₂ and with the free allocation CBAM factor increasing annually, net costs per tonne of BF-BOF steel escalate from approximately €3.50 in 2026 to approximately €71.75 in 2030 (when the CBAM factor reaches 48.5%) and approximately €140 per tonne at full phase-out in 2034.
The practical compliance steps for Polish authorized declarants are listed below.
- Confirm authorization status with KOBiZE and verify the CBAM account is active in the registry
- Map every import flow by CN code, production installation, and origin country for 2026 calendar year
- Contact each Ukrainian and Russian production installation to assess whether actual emissions data is available and verifiable
- Identify and engage an accredited verifier for each installation supplying actual data, noting that verifier registration opens September 1, 2026
- Prepare for default values on any Ukrainian installation unable to provide verified data due to conflict disruption
- Model certificate purchase requirements for 2027 using 2026 quarterly average ETS price data
- File the annual CBAM declaration by September 30, 2027 via the CBAM Registry with KOBiZE
- Retain all CBAM records, including customs declarations, emissions data, verification reports, and certificate confirmations, until the end of the 4th year following the declaration year
Contextual Border: How Polish Importer Obligations Compare Across CBAM Sectors
Poland's CBAM exposure extends beyond steel, though steel represents the dominant category by volume. Polish importers handling cement clinker, primary aluminium, nitrogen fertilizers such as urea and ammonium nitrate, or hydrogen from third countries face sector-specific compliance requirements that differ from steel in their emissions scope and default value structures.
CBAM Sectors Beyond Steel Relevant to Poland
Cement imports from Ukraine, where clinker production uses coal-fired kilns, carry both direct and indirect embedded emissions under CBAM, unlike steel where only direct emissions are priced. Fertilizer imports from Russia face compounding pressure: EU additional tariffs on Russian and Belarusian fertilizers rose to €40 to €45 per tonne effective July 2025 and escalate toward €315 to €430 per tonne by July 2028, stacked on the 6.5% ad valorem duty and CBAM certificate obligations. Polish agricultural importers purchasing urea or ammonium nitrate from Russian suppliers face the highest combined compliance cost of any CBAM sector by unit weight, with the gross CBAM cost for urea at approximately €175 per tonne at €70/tCO₂ before any free allocation adjustment.
Polish importers managing multiple CBAM sectors benefit from applying a consistent data collection process across all product flows. The CBAM compliance checklist provides a sector-by-sector checklist structured around the 11-step importer obligation framework from Regulation (EU) 2023/956.
Does the De Minimis Threshold Apply to Small Polish Importers?
Small Polish importers whose total annual imports of CBAM goods fall at or below 50 tonnes in net mass per calendar year are exempt from all CBAM obligations under Article 2(3a) of the regulation as amended by Regulation (EU) 2025/2083. The 50-tonne threshold applies per importer across all CBAM sectors combined, not per sector separately. Electricity and hydrogen carry no de minimis threshold regardless of volume.
Polish importers near the 50-tonne boundary must track cumulative annual import volumes across all CBAM CN codes in real time. The threshold applies to net mass, not product value, so a small importer purchasing high-value specialty steel in modest quantities may exceed 50 tonnes without realizing it if they also import other Annex I products. Exceeding the threshold in any calendar year activates the full authorization and declaration obligations for that year. The authorized declarant authorization process details what that transition from de minimis exempt to fully obligated status requires in practice.
Are CBAM Default Values a Viable Long-Term Option for Polish Importers?
Default values are a financially viable short-term option for Polish importers who cannot obtain verified actual emissions data, but the mark-up penalty schedule makes defaults increasingly costly over time. In 2026, using default values at the 10% mark-up level above the calculated baseline produces a certificate obligation that, in some product categories, may be lower than what actual verified emissions would generate, because the 2026 free allocation adjustment is so small. This paradox reverses from 2027 onward, when the 20% mark-up on already-elevated defaults begins to exceed actual low-emission values for efficient producers.
Polish importers sourcing from Ukrainian or Russian steelmakers with above-average carbon intensity may find that default values in 2026 are not materially different from actual values. Those importing from more efficient producers, including certain Ukrainian electric arc furnace (EAF) operations with emission factors near 0.5 tCO₂/t, save significantly by investing in actual data collection and verification. The CBAM default values for steel reference provides the current country-specific default values alongside the mark-up schedule through 2028. The CBAM steel importers section addresses how Polish steel importers can model the cost differential between defaults and verified actual values across Ukrainian and Russian origin shipments.
Is Poland Subject to Increased CBAM Enforcement Risk?
Poland operates KOBiZE as its NCA under an environmental protection institutional structure, consistent with 20 of the 27 EU member states that designated environment or energy departments to manage CBAM. KOBiZE's experience administering EU ETS compliance since 2005 gives it institutional capacity and an existing relationship with large industrial and commercial operators that is relevant to CBAM enforcement.
The Commission conducts cross-border anomaly analysis across the full EU CBAM Registry and flags suspicious patterns to individual NCAs. Polish importers whose declared embedded emissions are significantly below country-specific default values without supporting verification reports attract NCA attention. KOBiZE holds sweeping inspection rights under Article 15 of the regulation: it may request any retained CBAM document at any time during the 4-year post-declaration retention period, without advance notice.