The transitional period of the carbon border adjustment mechanism (CBAM) started on 1 October 2023 and will last until 31 December 2025.


CBAM aims to reduce carbon emissions by applying the same carbon costs to imported goods as to goods produced in the EU. CBAM-goods include mainly carbon-intensive goods imported from non-EU countries, with the exception of goods originating from Iceland, Norway, Liechtenstein, Switzerland and some special territories. Specifically, these include cement, iron and steel, aluminum, fertilizers, electricity and hydrogen.

During the transitional period, CBAM-obligation is limited to reporting certain data, e.g. the type and quantity of imported goods, the direct and indirect emissions embedded in those goods and any carbon price for those emissions, on a quarterly basis. There is no payment obligation in this period.

In mid-August, the European Commission adopted an Implementing Regulation which details this reporting obligation and provided a provisional methodology for calculating embedded emissions. The CBAM-report is to be submitted by the end of the month following the quarter. The first reporting deadline for CBAM-goods imported in Q4 2023 is 31 January 2024. Customs will notify importers about the reporting obligation at the time of import. Not complying with the reporting obligation or reporting incorrect or incomplete data could result in penalties.

As of 1 January 2026, only importers having a status of ‘authorized CBAM-declarant’ can import CBAM-goods. In order to acquire this status, registration is required beforehand, and may be available as of 1 January 2025.

Authorized CBAM-declarants should buy CBAM-certificates corresponding to the tonnes of CO2e embedded emissions in imported CBAM-goods. Thereafter, they should submit a CBAM-declaration concerning the embedded emissions in their imported CBAM-goods on an annual basis. With regards to calendar year 2026, the first CBAM-declaration should be submitted by 31 May 2027.

Compliance with the CBAM-rules requires preparation on the part of importers.

Feel free to contact us if you require further details about this new obligation.

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