In October 2022 I wrote an article about the upcoming CBAM and how it works. At the time, relatively little was known about this legislation and a lot of work still had to be done to get it ready in time for the planned implementation. In the meantime, despite the fact that quite a few elements are still unclear, a lot has been changed in the definitive CBAM regulation (May 2023). It will be introduced in October this year. This regulation is one of the pieces to reinforce the ambitious Green Deal package and to achieve the ultimate goal of a fully climate-neutral EU.

The regulation

The CBAM regulation will come into effect on October 1, 2023, after which parts will be implemented in phases. For example, as from 31 October 2023 to the end of 2025, there will be a first phase in which the reporting obligation will apply to importers. The importer will have to submit a report no later than 1 month after each quarter, including the emission information regarding the goods imported that quarter. From 2026, the complete CBAM system will be introduced, which will also include the obligation to declare.

Goods in this case

In my previous article, which you can read here, I described the product groups that will be affected by these measures. A list of products has been included in Annex 1 of the regulation, which you can use to verify whether you, as an importer, have to prepare for this. This list may be expanded in the future. It is not inconceivable that the European Commission will extend this legislation to other product groups (such as plastic), where the impact will be enormous.

Declaration obligation

As of January 1, 2026, the annual declaration obligation will be made mandatory for the CBAM declarant. This declaration contains the information regarding the (CBAM) goods that were imported in the previous calendar year. In addition, the emissions emitted must be stated in each declaration. The final CBAM certificates will be kept in a register.

The CBAM framework is gradually taking shape and you, as an importer, will have to make every effort to comply with these far-reaching measures. However, much is still unclear. It is therefore important to stay up-to-date. If you are affected by this new legislation and need support with it, you can contact us. Do you want to completely outsource this? Then our specialists will be happy to take over for you. Please contact me or one of our other specialists to discuss the possibilities.

27 Jun 2023 at 2:43 pm

2 min