One administrative update, several levels of authority

On 13 October 2026, the Financial Administration of the Republic of Slovenia (FURS) brought together new European guidance, verification rules, corrected default values, the de minimis assessment and the third-quarter certificate price. The overview is useful for Slovenian operators, but the cited materials do not all have the same legal status. The consolidated CBAM Regulation and its implementing acts are binding, while Commission guidance explains how those rules may be implemented without replacing the legislation. [SI_FURS] [EU_REG] [EU_GUIDANCE]

The definitive regime applies to covered imports from 1 January 2026. Each compliance control should therefore be tied to the relevant instrument and date: scope and exemption in the basic Regulation, calculation and verification under the applicable acts, default values in their corrected version, and the published price for the quarter of importation. A recent news page may identify a development, but it cannot by itself determine the obligations of a particular importer. [EU_REG] [SI_FURS] [EU_LEGISLATION]

The 50-tonne threshold is not a free band for the first tonnes

Article 2a of the CBAM Regulation exempts an importer where the cumulative net mass of the relevant goods does not exceed the single 50-tonne mass-based threshold during a calendar year. Commodity codes are aggregated per importer; electricity and hydrogen are outside this exemption. If the threshold is exceeded during the year, the Regulation applies to the emissions embedded in all covered goods imported during that year, not merely to the quantity above 50 tonnes. [EU_REG]

On 30 September 2026, the Commission reported that, for the period from 1 April 2025 to 31 March 2026, the threshold would have exempted 0.87% of embedded emissions, below the regulatory 1% limit. No amendment was therefore announced. The assessment does not remove the need to monitor mass from the start of the year, consolidate imports across the relevant codes and anticipate a late threshold crossing that would bring the whole year into the CBAM compliance perimeter. [EU_ASSESSMENT] [EU_REG]

Actual values require evidence before the declaration is filed

For goods other than electricity, Article 7 allows embedded emissions to be determined using actual emissions or default values. Where actual emissions are declared, Article 8 requires those emissions to be verified by an accredited verifier. FURS warns that false verification reports are circulating and explains that the communication template used during the transitional period is not, by itself, sufficient evidence for actual values in the definitive regime. [EU_REG] [SI_FURS]

The Commission’s guidance of 24 August 2026 addresses monitoring plans, risk analysis, site visits, materiality, reporting and accreditation. It is explanatory and not legally binding, but it provides a useful operating framework. FURS says that the first Slovenian accreditations are expected in November 2026; that timetable indication does not create a waiver. Importers, non-EU producers and verifiers should secure the data, reporting period, accreditation scope and audit trail before the first declaration. [EU_VERIFY_GUIDE] [SI_FURS] [EU_REG]

Corrected default values apply from 1 January 2026

Commission Implementing Regulation (EU) 2026/1740 of 20 July 2026 corrects Implementing Regulation 2025/2621. It replaces Annexes I and IV to fix missing or incorrect production-route indicators, omissions and transcription errors, unclear units and certain CN or TARIC code mappings. Published on 31 July, it expressly applies from 1 January 2026. Calculations already started for 2026 imports must therefore be reconciled with the corrected version. [EU_CORRECTION] [EU_LEGISLATION] [SI_FURS]

The corrected annex states that the selected total-emissions default value is increased in 2026 by 10% for cement, iron and steel, aluminium and hydrogen, and by 1% for fertilisers. These percentages are mark-ups to default emissions values, not tax rates. A business should retain the product code, origin, relevant production route and version of the table used so that it can explain any change in its estimate. [EU_CORRECTION]

EUR 82.32 is a certificate price, not an immediate border payment

On 5 October 2026, the Commission published a CBAM certificate price of EUR 82.32 for the third quarter of 2026. For emissions embedded in goods imported during 2026, Article 21 links the price to the quarterly average closing prices of EU ETS allowances in the quarter of importation. Imports must therefore be allocated by quarter. Multiplying EUR 82.32 by tonnes of goods would be wrong: the price applies to certificates corresponding to tonnes of CO2e after the relevant adjustments. [EU_PRICE] [EU_REG]

Payment timing must be kept separate from economic measurement. The common platform will begin selling certificates on 1 February 2027. The first CBAM declaration and surrender, covering 2026, are due by 30 September 2027. The 2026 quarterly price therefore values certificates associated with imports in that quarter; it is neither a customs duty collected at the border nor the final liability of a case before embedded emissions, any carbon price effectively paid abroad and the free-allocation adjustment have been calculated. [EU_REG] [EU_PRICE]

The practical control file for Slovenian importers

For each import, the compliance file should connect the named importer, CN or TARIC code, origin, net mass, quarter, emissions method and data source. An annual counter should warn before 50 tonnes. If actual values are used, the file should identify the installation, verifier, accreditation scope and positive report. If defaults are used, it should record the corrected table and any relevant production route. Cash planning should then separate the 2026 estimate, certificate purchase and the 2027 surrender. [EU_REG] [EU_CORRECTION] [EU_VERIFY_GUIDE]

This analysis does not calculate the obligation of an identified importer. The outcome depends on the goods, codes, origin, annual mass, emissions, available evidence, the carbon price effectively paid in the third country and the free-allocation adjustment. The August 2026 guidance remains non-binding and prices change by quarter. Before filing, the current Regulation and its secondary acts, CBAM Registry data and Slovenian authority instructions should therefore be checked rather than relying on a summary or a transitional-period template. [EU_REG] [SI_FURS] [EU_GUIDANCE] [EU_PRICE]