Who needs to comply with CBAM?

Any EU importer (or their indirect customs representative) bringing CBAM-covered goods (cement, iron, steel, aluminium, fertilisers, electricity, hydrogen) into the EU customs territory.

What happens if I don't submit a CBAM report?

During the transitional period, failure to submit a report or submitting an incomplete/incorrect report can result in penalties ranging from €10 to €50 per tonne of unreported emissions.

Can I use default values for emissions?

Default values can be used extensively in the early transitional period, but their use is strictly limited later. Importers must transition to using actual emissions data from producers.

CBAM Compliance Checklist

The Carbon Border Adjustment Mechanism (CBAM) is a landmark EU regulation designed to put a fair price on the carbon emitted during the production of carbon-intensive goods entering the EU. This checklist provides a step-by-step guide for importers to ensure compliance during both the transitional and definitive periods.

Phase 1: Preparation and Assessment

Identify CBAM Goods: Check if your imported goods fall under the CBAM scope (cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen) using the CN codes listed in Annex I of the regulation.
Map the Supply Chain: Identify the installations in non-EU countries where the goods are produced. You will need detailed data from these operators.
Establish Internal Responsibilities: Assign clear roles within your organization for data collection, reporting, and verification.

Phase 2: Data Collection (Transitional Period)

During the transitional period (1 October 2023 to 31 December 2025), importers must report emissions but do not pay financial adjustments.

Request Emissions Data: Ask non-EU producers for data on direct and indirect embedded emissions. The EU provides a communication template for this purpose.
Calculate Embedded Emissions: Use the EU methodology to calculate the specific embedded emissions of the imported goods. If actual data is unavailable, use default values (allowed under specific conditions and timeframes).
Track Carbon Prices Paid Abroad: Document any carbon price already paid in the country of origin, as this can offset the CBAM obligation.

Phase 3: Reporting and Registration

Access the CBAM Transitional Registry: Ensure you have the necessary national access rights to log into the CBAM portal.
Submit Quarterly Reports: Submit the CBAM report no later than one month after the end of each quarter. The report must include total quantities imported, total embedded emissions, and any carbon price paid abroad.
Apply for Authorized Declarant Status: Before the definitive period begins on 1 January 2026, apply to become an "authorized CBAM declarant" through your national competent authority. Only authorized declarants can import CBAM goods after this date.

Phase 4: Definitive Period (From 2026)

Purchase CBAM Certificates: Buy sufficient CBAM certificates to cover the embedded emissions of your imported goods. The price is based on the weekly average auction price of EU ETS allowances.
Verify Emissions Data: Ensure that the total embedded emissions declared are verified by an accredited verifier.
Submit Annual Declaration: By 31 May each year, submit the annual CBAM declaration for the preceding calendar year and surrender the corresponding number of certificates.