CBAM transitional period is over – is your organization ready?

Reminder: What exactly is CBAM?

CBAM (Carbon Border Adjustment Mechanism) is an EU measure concerning the reporting and settlement of CO₂ emissions from goods produced outside the EU.

It is intended to:

  • Prevent unfair competition between EU companies and companies outside the EU with less strict emission rules.
  • Reduce CO₂ emissions worldwide.
  • Strengthen the functioning of the EU Emissions Trading System (EU ETS).

Who does CBAM apply to?

CBAM applies to importers of CBAM goods. These are goods in the categories: iron and steel, cement, fertilizers, aluminium, electricity, and hydrogen.

Exemption: < 50 tonnes (goods weight) imported into the EU per year = largely exempt from reporting.

Timeline

From 1 January 2026:

  • Annual CBAM declaration is mandatory (for 2026, due before 30/09/2027)
  • Only authorised (registered) CBAM declarants may import CBAM goods.
  • Mandatory inclusion of the CBAM account number and TARIC code in every import declaration. Customs checks this automatically
  • Importers bringing in less than 50 tonnes per year are exempt from CBAM authorisation and obligations (does not apply to electricity and hydrogen).

From 1 January 2027:

  • From 2027: purchase of CBAM certificates (also for 2026!)
  • > 50 tonnes/year = quarterly requirement to hold sufficient CBAM certificates

Important points of attention

  • The HS code determines CBAM applicability
  • Importing 50 tonnes or more without authorisation = Customs will reject declarations
  • CBAM authorisation application: maximum processing time 120 days

What you must do if you import CBAM goods

  • Register as an authorised CBAM declarant with the emissions authority.
  • Ensure all required CBAM data is included in customs declarations.
  • Set up and manage the 50 tonne threshold monitoring.
  • Organise reporting and emission data.

Risks of non compliance with CBAM regulations

  • Blocking of goods at the border
  • Enforcement by the NEA (violation of Article 26)
  • Administrative fines and possible additional sanctions
  • Import ban above the 50 tonne threshold without authorisation
  • Financial risks and future certificate costs due to incorrect emission data

All information about CBAM and its obligations can be found below