Since October 2023, importers of carbon-intensive goods into the EU are required to report on the carbon emissions produced during manufacture of the goods outside of the EU. This mechanism initially applies to a selected number of goods in sectors at high risk of carbon leakage, i.e.  iron/steel, cement, fertilizers, aluminium, hydrogen and electricity.

Currently in its transitional phase until the end of 2025, the definitive period will commence on January 1, 2026.

• Transitional phase – Importers are required to declare quarterly the emissions of imported goods within scope without having to pay for these emissions.

• Definitive period – Importers will need to purchase CBAM certificates corresponding to the carbon price that would have been paid had the imported goods been produced under the EU’s carbon pricing rules, provided a non-EU producer has not already paid a carbon price in a third country on the embedded emissions.

The CBAM reporting obligation is complex with declarations requiring verification and noncompliance open to financial penalties.

For an in-depth look at whether you are in scope and how we can assist you, read the full insight on our website.