What is this all about?
As part of the Green Deal, the EU introduced a CO2 border adjustment system called CBAM (Carbon Border Adjustment Mechanism) effective as of 1 October 2023. The aim is to price emission-intensive products produced outside the EU in the same way as products produced in the EU with a CO2 tax. This is to prevent competitive disadvantages for EU companies.
Who is affected by this?
In the first step, this regulation affects importers of certain goods from a third country, according to Annex I of Regulation (EU) 2023/956. These include:
- Cement
- Electricity
- Fertiliser
- Iron and steel, including certain products made from these materials (e.g. pipes, barrels, screws)
- Aluminium, including certain products made from this material (e.g. storage receptacles, cans, cables, but also decorative articles)
- Hydrogen.
You can check whether you are concerned with your imported goods by means of CN codes defined in Annex I of the CBAM Regulation.
What are the obligations of importers of goods concerned, and what deadlines apply?
Even though most of the regulations will not take full effect until 1 January 2026, the following obligations must already be observed in a transitional phase:
- Reporting obligation without financial obligations: by 30 January 2024 at the latest; importers concerned must submit a first CBAM report. Direct and indirect emissions that occur in the course of the production process of the imported goods must be determined and documented in this report.
CBAM reports are to be submitted on a quarterly basis after this first report.
- Registration obligation: from 1 January 2025, imports will only be possible for registered declarants.
- Certificate trading/compensation payments: from 1 January 2026.
What should be done by the companies concerned as a first step?
- Check your level of concern. If your imported products do not fall under the established CN codes, or if other exceptions apply, the CBAM Regulation does not apply to you.
If you fall under this regulation, please contact trade-e-bility. We support and advise in the supply chain on the right way to deal with the supplier: Please call +49/40/750687-300 or send an e-mail to beratung@trade-e-bility.de
