What is CBAM?

CBAM (Carbon Border Adjustment Mechanism) is a mechanism for carbon adjustment at the EU’s borders. The mechanism ensures additional taxation of imports of carbon-intensive goods in the form of mandatory purchase of CBAM certificates. The EU aims to ensure equal treatment of carbon-intensive goods regardless of where they are produced. The ultimate goal of CBAM is the decarbonization of the EU and its economic partners.

 

How does CBAM work?

From January 2026, imports of carbon-intensive goods are subject to the CBAM mechanism. Importers are required to purchase the appropriate number of CBAM certificates corresponding to their imports.

The number of CBAM certificates depends on:

1. the quantity of imported goods;
2. the amount of embedded emissions generated during the production of the goods in the third country;
3. the adjustment for the gradual phase-out of free allocation under the EU Emissions Trading System (EU ETS); and
4. any carbon price or environmental charges already paid in the country of origin.

 

What are carbon-intensive goods?

• Cement
• Electricity
• Fertilizers
• Iron and steel
• Aluminium
• Hydrogen

 

How do we know if we imported CBAM goods?

In box 33 of the import customs declaration, you can find the tariff code of the imported goods. This code should be compared with the list of CBAM goods in Annex 1 to Regulation (EU) 2023/956. If the imported goods appear on the list in Annex 1, they are subject to CBAM reporting.

 

More about CBAM

CBAM – The EU’s mission for global decarbonization (Part 1): CBAM obligations of importers in the transitional phase

CBAM – The EU’s mission for global decarbonization (Part 2): CBAM obligations of importers in the definitive phase

Who is responsible for CBAM reporting?

The CBAM reporting obligation generally applies to the importer of goods who releases the goods for free circulation within the EU.

Importer established in the EU:
For importers based in the EU, the role of the CBAM declarant may also be assumed by an indirect customs representative (freight forwarder). If the indirect customs representative does not wish to take on this role, the importer remains responsible for fulfilling CBAM obligations.
The importer may also authorize a third party, such as an accounting service, to handle CBAM reporting on their behalf.
Check how we can assist you.

Importer established in a third country:
For importers from non-EU countries, the indirect customs representative (freight forwarder) is responsible for CBAM reporting.

 

Transitional and definitive phase

Transitional phase (October 1, 2023 to December 31, 2025):

• Aimed at learning, coordinating all involved parties, and adapting legislation.
• Quarterly reporting of emissions without financial consequences for importers.

Definitive phase (from January 1, 2026 onwards):

• Gradual phasing out of free allowances under the EU ETS.
• Annual reporting of emissions and mandatory purchase and submission of CBAM certificates.