CO2 border adjustment system – Carbon Border Adjustment Mechanism (CBAM)

The CBAM introduces a levy on imports of certain goods. Initially, iron and steel, cement, aluminum, fertilizers, electricity and hydrogen will be affected. The customs tariff numbers covered by CBAM are listed in Annex I of EU Regulation 2023/956 (page 39).

It is expected that the list of tariff numbers covered by CBAM will be expanded from 2026. By 2030, all goods covered by the EU Emissions Trading Scheme will be included.

Goods originating from the EFTA or EU (according to the EU’s non-preferential origin rules) will be exempt from the CBAM.

The CBAM rules will apply from October 1, 2023, with a transitional period until December 31, 2025. During the transitional period, importers or indirect representatives (e.g. in the case of non-resident importers) must report the importation of the goods affected into the EU on a quarterly basis via a CBAM report. The report must contain, inter alia, the following information about imported goods:

• Quantity imported
• Direct emissions
• Indirect emissions
• CO2 price paid abroad

Starting from January 1, 2027 (previous date: January 1, 2026), EU importers must financially offset direct or indirect emissions caused by the production of imported goods by purchasing CBAM certificates in advance.

As stipulated by Commission Implementing Regulation (EU) 2025/486, as of 1 January 2026, only “approved CBAM notifiers” may import goods affected by CBAM into the EU. Importers based outside the EU need an indirect customs representative to carry out the necessary registration.

To explain the scheme, the EU has published guidance for EU importers and an e-learning (nano-learning module) in English.

The “Omnibus” package

The “Omnibus” package will greatly simplify administrative matters. Since January 1, 2026, a new threshold of 50 tons per year exempts smaller importers from the reporting obligation.

An overview of the changes made by the Ominbus package can be found here.