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The Border Carbon Adjustment Mechanism (CBAM) was set up at European level and targets imports of more carbon-intensive products. Its aim is to extend the EU’s greenhouse gas reduction targets to imports of products manufactured in third countries, and it will gradually replace existing EU schemes.


All products in the cement, electricity, fertilizer, steel, aluminum and hydrogen sectors are concerned by this mechanism when these goods originate in third countries and are released for free circulation on EU customs territory. A specific framework is in place for inward-processing products released for free circulation.

However, a minimum threshold is set, exempting shipments worth less than €150 from CBAM obligations. This measure would reduce administrative complexity, as it would concern a third of shipments to the Union, representing a small proportion of greenhouse gas emissions compared with total imports of these products into the Union.

Importers of CBAM products to the EU and indirect customs representatives are directly concerned by this mechanism.


As this is an EU-wide scheme, the CBAM registration platform is a single European platform, and the new register of CBAM declarants (importers) will be centralized at this level.

Implementation will be very gradual, starting with a transitional period between October 1, 2023 and December 31, 2025, during which quarterly reporting will be mandatory for customs declarations. From January 1, 2025, a “CBAM declarant” authorization will be required.

Effective operation will begin on January 1, 2026, with a predefined process:

  • CBAM Authorized Declarer” status issued
  • Purchase of CBAM certificates, with an obligation to hold a minimum stock of CBAM certificates each quarter
  • Annual CBAM declaration and verification by an accredited auditor
  • Return and request for reimbursement of CBAM certificates
  • Settlement of any penalties

A timetable is also available for importers, who will have to follow it to be able to continue their import activities:

  • From October 1, 2023: register on the CBAM platform
  • Before January 31, 2024: calculate imported emissions and draw up the CBAM report (then do so every quarter after January 31, 2024)
  • July 31, 2024: correct declaration
  • 1st quarter 2025: collect supporting documents and submit “CBAM declarant” application
  • During 2025: be alert to any requests for additional information, in order to obtain authorization before import in 2026
  • March 31, 2026: purchase sufficient CBAM certificates to verify minimum stock conditions
  • Before May 31, 2027: submit verified CBAM declaration, any refund claims and return certificates

Our customs experts can advise and assist you with all your customs formalities.

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