Vietnam-to-Italy shipments: a 2026 CBAM pre-booking checklist

The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026. For Vietnamese exporters selling covered goods to Italy, CBAM is formally the EU importer's obligation, but the usable product and emissions data start upstream at the factory. That makes the period before a freight booking the best moment to close information gaps.

The current scope covers specified CN codes in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. For cement, fertilisers, iron and steel, and aluminium, the 50-tonne threshold is measured cumulatively per importer across those sectors during the calendar year. Electricity and hydrogen do not use that mass threshold. If the threshold is exceeded, the regulation applies to all covered imports by that importer in that year, including the quantities imported before the crossing point.

The pre-booking file

• Confirm the eight-digit CN code with the Italian importer or customs representative; do not decide CBAM scope from a commercial product name alone.
• Record the importer of record, EORI number, Italian entry point and customs-representation model. Ask the Italian party to confirm its CBAM account or application status where required.
• Reconcile the net mass in the commercial invoice, packing list, transport document and customs data. The threshold is annual and importer-wide, not a per-shipment allowance.
• Identify the producing installation, country of origin and production route for every covered line item. Keep lots separate if they come from different plants or production routes.
• Agree in writing whether the importer will use Commission default values or actual emissions data for the 2026 declaration.
• If actual values are planned, assign ownership for the operator's emissions report, supporting calculation records and access for an accredited verifier. Do not label internal estimates as verified data.
• Keep version-controlled evidence with the shipment file and name one contact in Vietnam and one in Italy for later questions.

Why this cannot wait until customs clearance

The European Commission says the first CBAM declaration, covering 2026 imports, and the corresponding certificate surrender are due by 30 September 2027. Importers may use Commission default values or actual values; actual values require verified total embedded-emissions data from the producer. The Commission said on 30 June that the first accredited CBAM verifiers were expected around September 2026, while Italy's accreditation body has been processing verifier applications during 2026.

This creates a practical sequencing issue. A shipment can move months before the annual declaration, yet factory evidence may be difficult to reconstruct after production teams, suppliers or calculation files change. Exporters should therefore treat CBAM data as a shipment-file requirement even though verification and surrender happen later.

What the published price does—and does not—tell you

The Commission published a CBAM certificate price of EUR 75.36 per tonne of CO2 for Q1 2026 and EUR 75.28 for Q2. These are official quarterly reference prices for emissions in goods imported during the respective quarters. They are not a freight surcharge and cannot by themselves produce a shipment-level CBAM cost. The final obligation depends on the regulated emissions calculation, applicable adjustments and any eligible carbon price already paid in the country of production.

Use those prices for sensitivity planning with the Italian importer, not as a carrier charge or a guaranteed invoice amount.

Italy-specific handoff

Since 6 May 2026, Italy's national competent authority is the ETS Committee, Section 2, known as the CBAM Committee. The Italian authority's portal publishes authorisation acts and operator guidance. The importer or indirect customs representative should own the Italian authorisation, registry and declaration process; the Vietnamese supplier should own the accuracy and traceability of the production data it provides.

Before booking, ask both sides to sign off on four points: CN-code scope, annual threshold position, chosen emissions-data route, and responsibility for correcting missing or inconsistent records. This will not guarantee faster customs clearance, but it reduces the risk that freight moves with an incomplete compliance file.

Confidence and limits

Confidence is high for the dates, threshold structure, covered sectors, published certificate prices and Italian authority information because they come from EU law, European Commission pages and Italian official bodies. Confidence is medium for the operational recommendation to complete the file before booking; it is an evidence-based workflow recommendation, not a legal deadline. This guide is not legal, customs or emissions-verification advice, and it does not predict a specific delay, surcharge or certificate liability for any shipment.