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CBAM on Taiwan fasteners in 2026: the bill is not 2.5%

On EU default values, a tonne of Taiwan bolts imported in 2026 carries about €132 of CBAM cost, roughly 5% of what that tonne sold for. Here is where the number comes from, and what you can still change.

Updated October 9, 2026. Figures follow the EFDA cost guide of March 2026 and the default values in Implementing Regulation (EU) 2025/2621.

The short version

  • If your company imports more than 50 tonnes of CBAM goods a year, fasteners under heading 7318 included, every tonne imported since January 1, 2026 carries a CBAM cost. At 50 tonnes or less you're out.
  • The 97.5% "free allocation" in 2026 is applied to an EU benchmark, not to your goods. Anything your supplier emits above that benchmark is billed in full.
  • On Taiwan's default value, that is about €132 per tonne for 2026 imports, rising to about €183 for 2028 imports at the same certificate price.
  • Actual supplier data would lower it, but it has to be verified, and verifiers only started being accredited in late September 2026.
  • The data you need sits mostly with the steel mill, not the fastener maker. Start asking now, for 2027.

If you've read about CBAM's first paying year, you've probably seen the reassuring version: in 2026 importers only pay for 2.5% of emissions. That isn't how the formula works. The 97.5% is subtracted from a benchmark set by the EU's cleanest steel plants, so the gap between your supplier and that benchmark is billed almost in full from day one.

This note works through what that means for fasteners bought from Taiwan. We cover who is in scope, the formula with a Taiwan bolt in it, what it adds per tonne through 2028, why actual supplier data probably won't rescue 2026, and what to ask your supplier now so 2027 looks different.

First, check you're over 50 tonnes

The October 2025 simplification, Regulation (EU) 2025/2083, took most importers out of CBAM altogether. If your total imports of CBAM goods (everything in scope except electricity and hydrogen) stay at or below 50 tonnes of net mass in a calendar year, you don't need to be an authorised CBAM declarant and you don't buy certificates. The Commission estimated that about 90% of importers fall below the line, while about 99% of embedded emissions stay in scope.

For fastener buyers the line arrives quickly, because bolts are heavy for their price. If a container carries, say, 18 tonnes of fasteners, three containers a year put you over. The threshold counts all your CBAM goods together, not one supplier or one product at a time.

If you are over it, the rest of this note is about your 2026 bill.

The formula, with a Taiwan bolt in it

Being in scope tells you that you pay, not how much. The European Fastener Distributor Association (EFDA) laid the calculation out for its members in March 2026. Per tonne of imported fasteners:

CBAM cost = (emissions per tonne − benchmark × CBAM factor) × certificate price − carbon price already paid abroad

EFDA's own Example 1 is a tonne of Taiwan screws and bolts under CN 7318 14 99, imported in 2026 on default values:

Part of the formulaValueWhere it comes from
Emissions per tonne2.978 t CO₂Taiwan default value for 2026, including the 10% mark-up (Reg. 2025/2621)
Benchmark1.364 t CO₂Blast furnace route, the one most fasteners fall under (Reg. 2025/2620)
CBAM factor0.975The 2026 level of free allocation in the EU ETS
Certificate price€80EFDA's illustrative price; 2025 trading ran between about €60 and €85
Carbon price paid abroad€0Deduction rules not yet settled
CBAM cost€131.85(2.978 − 1.364 × 0.975) × 80

Look at the bracket. The free allocation removes 1.33 tonnes of CO₂, which is 97.5% of the benchmark. The Taiwan default is 2.98 tonnes, so 1.65 tonnes are left to pay for. In other words, you aren't paying for 2.5% of your bolts' emissions. You're paying for more than half of them.

Taiwan began collecting its own carbon fee in 2026 on large emitters' 2025 emissions, at a standard NT$300 a tonne. Could that be the "carbon price paid abroad"? Not yet in practice. EFDA notes that the deduction rules are still being finalised, and any deduction would depend on documenting what was actually paid on the steel in your shipment. We set it to zero here, as EFDA does.

What it adds per tonne, 2026 to 2028

€132 a tonne is the first year. The default values climb with a mark-up of 10% in 2026, 20% in 2027 and 30% in 2028, while the CBAM factor falls. Holding the certificate price at €80 so only the rules move:

Import yearTaiwan defaultCBAM factorCost per tonne
20262.9780.975€132
20273.2490.950€156
20283.5190.900€183

To size that against the goods: Taiwan's steel fastener exports to Germany from January to August 2025 came to US$242 million for 76,309 tonnes, about US$3,170 a tonne. At an assumed US$1.15 to the euro, €132 is close to 5% of that, and €183 is closer to 7%. A cheaper product, or a higher certificate price, pushes the share up.

For a whole year, take a hypothetical importer bringing in 400 tonnes of Taiwan fasteners in 2026. On default values that's about €52,700 in certificates. None of it has to be bought until February 2027, which is exactly why it's easy to forget to set it aside now.

Why actual supplier data probably won't save 2026

The obvious way to shrink the bill is to replace the default with your supplier's real, lower emissions. In EFDA's hypothetical example for a Vietnamese bolt, actual data cut the 2026 cost from €136 to €52 a tonne. The catch is that real data only counts once an accredited verifier has checked it, and according to EFDA, for 2026 imports the verifier has to visit every relevant installation in person.

That creates a timing problem. Under the Commission's timetable, accredited verifiers could start reviewing documents and visiting sites from September 2026 and issue the first reports from January 2027, and the declaration for 2026 imports is due by September 30, 2027. Accreditation itself only got going in late September 2026, when the Greek firm EmiCert announced it had become the first accredited CBAM verifier. The window is about a year, and it opened with very few people able to work in it.

For fasteners the visits don't stop at the bolt factory. The emissions that count are mostly upstream: making the iron or scrap charge and casting the billet. The Commission has told EFDA that making the fasteners themselves sits outside the system boundary. As of EFDA's March guide, whether wire drawing sits inside was still unsettled. So the installation a verifier most needs to see is the steel mill. EFDA's view in March was that verified actual values for 2026 imports are "highly unlikely." The September start gives a few more months than EFDA counted on, but we can't predict how many verifiers will be working, or how many steel mills will be ready for them.

Plan your 2026 provisions on default values. Treat any verified data you do get as a refund on your own estimate.

What to ask your Taiwan supplier now

2026 is probably settled, but 2027 isn't. If you read our Section 232 note, the chain will look familiar. The papers you need run back through the same companies, from the fastener maker to the wire drawer to the steel mill, and they get lost at the same handoffs. Five things to ask for:

  1. Which mill made the wire rod for your parts, and by which route: blast furnace or electric arc. The benchmark and the data you need depend on it.
  2. Whether that mill will share installation-level emissions data and has a CBAM monitoring plan in place. Without a monitoring plan there is nothing for a verifier to check.
  3. Who drew and annealed the wire. If wire drawing ends up inside the system boundary, that shop's data will be needed too.
  4. How many tonnes of rod went into each tonne of finished parts. Precursor emissions are weighted by this input-output ratio.
  5. Records that show when the goods were made. According to EFDA, goods imported in 2027 but manufactured earlier can use the lower 2026 default value if you can prove the production date, with documents such as mill test certificates and raw material invoices. A mill certificate dates the steel, not the bolts, so ask for the production or lot record that ties the two together. It's the same certificate the Section 232 note asks you to keep for melt and pour, so that paperwork does double duty. It doesn't replace an emissions report or its verification.

A supplier that can answer the first two is one whose data has a realistic chance of being verified. One that can't is a supplier you'll be paying default values on for the foreseeable future, and that belongs in your next price negotiation.

So the number to carry into your 2027 budget isn't 2.5%. It's whatever your supplier's mill can prove to a verifier, and until it can prove anything, it's the default.

Need someone at the mill or the factory?

We visit Taiwan fastener makers and their wire rod suppliers, find out who holds which emissions and production records, and send you what we find in English, with photos. We don't verify emissions. We help get the data and the people ready for the verifier you choose.

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This is a plain-English summary for buyers, not legal, tax or customs advice. CBAM implementing rules are still changing. Confirm your obligations with your customs adviser and your national competent authority.

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