As of 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM) enters its definitive phase. From that date, CBAM goods may only be imported into the EU by importers or indirect customs representatives holding the status of an approved CBAM importer, unless an explicit exemption applies.
What is CBAM?
To achieve climate neutrality across the entire economy by 2050, the European Union has established a Carbon Border Adjustment Mechanism (CBAM). This mechanism ensures that a fair price is applied to the carbon emitted during the production of carbon-intensive goods imported into the EU. It aims to create a level playing field for imported goods within the EU customs territory while encouraging cleaner industrial production in third countries.
The list of CBAM goods can be found in Annex 1 of the regulation, accessible via the link below. It includes, among others, certain products made of cast iron, steel, and aluminium.
After a temporary transitional period, CBAM will enter into full effect on 1 January 2026. Importers who submitted an application on time but have not yet received a decision may temporarily continue importing CBAM goods while awaiting a decision, except for electricity and hydrogen.
The status of approved CBAM importer
The CBAM status is linked to a unique CBAM account number in the European CBAM registry. From 1 January 2026, this number must be included in the customs declaration for each CBAM good, together with the correct TARIC codes.
What you need to do as an importer:
- Request the status of approved CBAM importer immediately if you have not done so yet.
- If you have obtained the status or submitted an application, provide this information to your customs declarant if you do not prepare your own declarations. The declarant will need to include it in declarations from 1 January 2026 onwards.
- Ensure that your customs processes and master data are correctly aligned before 1 January 2026.
- Implement a reporting system.
Important clarification regarding responsibilities
The correct application of CBAM and the identification of CBAM goods upon import remain entirely the responsibility of the CBAM importer. Given the scope of the relevant HS codes, we cannot independently verify whether goods fall under CBAM, nor whether an importer holds a valid authorization. We therefore rely on the information you provide to us at the time of import.
To support this process, we have prepared a standard declaration to be completed when importing potentially CBAM-relevant goods. You can access it via this link.
In this declaration, you confirm either that you import less than 50 tonnes per year, or that you are an approved CBAM importer, providing your CBAM account number. Incorrectly declaring an authorization or using a number without valid approval, may result in fines and/or severe penalties.
We cannot assume responsibility for the validity of CBAM authorizations, certificates, or associated emission reporting; these obligations rest entirely with the CBAM importer.
Note: The information above is provided for general guidance only and does not constitute specific advice or assistance regarding the practical implementation or compliance with CBAM obligations.