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The EU’s Carbon Border Adjustment Mechanism (CBAM) imposes a carbon price on imports of specific high-emission goods (e.g., steel, cement), ensuring they match EU producers’ carbon costs under the Emissions Trading System (ETS). Starting in 2026, CBAM’s phased rollout aligns with the elimination of free ETS allowances for EU industries, preventing carbon leakage while driving global decarbonization.
Fines of €10-50 per tonne for unreported emissions, with 2-month correction window.
Mandatory reporting during 2023-2025 transition, full enforcement from 2026.
The default value is no longer available, and the submission deadline for the next CBAM report is approaching swiftly.
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The CBAM Regulation applies to CN codes (Combined Nomenclature), which adds two digits to the HS code and is used as a commodity code for exports outside the EU. All goods for which the embedded emissions must be reported are listed in Annex I to the CBAM Regulation. These are called ‘CBAM goods’. Sectors such as ‘iron and steel’ are mentioned only for informational purposes. For example, this means that imports of ammonia (CN code 2814 10 00 or 2814 20 00 under the fertilizer sector) are covered by the CBAM Regulation even if the ammonia is not used to produce fertilisers.
Since 1 October 2023, reporting embedded emissions in CBAM-covered goods has become mandatory. Declarants who fail to comply may face financial penalties ranging from EUR 10 to EUR 50 per tonne of unreported emissions. If a CBAM report is missing, inaccurate, or incomplete, the national competent authority (NCA) may initiate a correction process, allowing the declarant to amend any identified issues. Penalties may still be applied if: (a) the declarant has not taken reasonable steps to submit the required report, or (b) the report remains incorrect or incomplete despite the opportunity to make corrections.
The following table provides an overview of the specific emissions and greenhouse gases covered and how direct and indirect emissions are determined for each sector falling under the CBAM scope. Each sector’s particularities have been taken into account when designing the methods for reporting and calculating embedded emissions in these goods while mirroring the EU Emissions Trading System.
It can be corrected. The CBAM report can be revised within 2 months after the end of each season. The first two reports during the transition period have buffer space and can be revised before the deadline of the third quarter report.
Reporting declarants may face penalties ranging between EUR 10 and EUR 50 per tonne of unreported emissions.
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