The first carbon border year ends in December. Here's what a small importer needs.

Picture a small steel stockist near Limassol. We'll call him Marios. He's made up, but his week isn't.
It's a Thursday in October. A container of rebar is due next week. Marios is doing what he always does: the invoice, the customs agent, the van. Somewhere in a Brussels regulation there is a number that now matters to him more than the price of steel. It's .
Here is how it works. Since 1 January 2026, the EU's carbon border rules apply to iron and steel, aluminium, cement and fertiliser coming in from outside the EU.12 An importer who brings in 50 tonnes or less of these goods in a calendar year, all added together, is exempt.3 Go over 50 tonnes and the rules cover everything imported that year, not just the tonnes above the line.
Going over means three jobs. First, the importer needs to be an before crossing the threshold.4 If customs see that someone has gone over without that status, they stop letting that importer bring the goods in until the end of the year or until the status is granted.5 For a stockist with a yard to fill, that is the real fear: rebar sitting at the port.
Second, there's a yearly declaration. It lists every tonne imported in 2026 and the carbon in it, and it's due by .6 The carbon can come from the mill's own measured figures, checked by an , or from the Commission publishes.7
Third, the importer to cover that carbon. Sales start on 1 February 2027, and the certificates are handed in with the declaration.8 From 2027 an importer also needs to hold certificates for at least half of the year's carbon at the end of every quarter.9
None of this is hard because it's clever. It's hard because it's scattered. The tonnes are on twelve months of invoices. The carbon figures sit with mills in other countries. The deadline is a year away, which is exactly how deadlines get missed.
This is the job we built Vuneli for. It gathers the import invoices and the emissions data from suppliers, and prepares the declaration from the firm's own records. As the year's tonnes get close to 50, it warns the importer, so the authorisation can be sorted before the line is crossed. When a rule changes, it says so early, not after the fine. Marios reads one page, fixes anything that looks wrong, and says yes.
The first year closes on 31 December. If your firm brings in steel, aluminium, cement or fertiliser, now is a good time to add up the tonnes.
Vuneli is a working product today. We're a small software company in Nicosia, and we're looking for Cypriot importers who want to try it with us.
Sources
- European Parliament and Council, EUR-LexRegulation (EU) 2023/956 establishing a carbon border adjustment mechanism
- 1The goods the rules cover: iron and steel, aluminium, cement and fertiliserAnnex IBack to text
- European Parliament and Council, EUR-LexRegulation (EU) 2025/2083 of 8 October 2025, amending Regulation (EU) 2023/956
- 2The rules apply from 1 January 2026Article 1(27), amending Article 36Back to text
- 3The 50 tonne threshold, and every tonne counting once it is crossedArticle 2a and Annex VIIBack to text
- 4Authorisation before going over the thresholdArticle 5Back to text
- 5Customs stop further importsRecital 9 and Article 25Back to text
- 6The yearly declaration, due by 30 September, first in 2027Article 6Back to text
- 7Default values or verified actual emissionsArticles 7 and 8Back to text
- 8Certificate sales from 1 February 2027Article 20Back to text
- 9Holding 50% of the year's carbon in certificates each quarter, from 2027Article 22Back to text
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