One Mechanism, Many Gateways: How CBAM looks different across Europe

CBAM is European law, but it reaches companies through national administrative systems. The regulation itself is centralised. Its implementation is not. For companies operating in a single Member State, this distinction may not immediately stand out. But once you compare how CBAM is handled across Europe, the differences become clear. They are not chaotic or inconsistent, yet they are distinctly national.

A digital mechanism that still begins locally

CBAM is designed as a digital system. The European Commission provides a central registry. Reports are submitted electronically. Deadlines are aligned across the Union.

Yet in several Member States, companies applying for Authorised CBAM Declarant status must first submit documentation to their local customs authority. Signed forms. Supporting documentation. Formal applications. This reflects how CBAM builds on existing national customs infrastructures. The portal is European. The gatekeeper remains national.

Romania: strict data reconciliation

Romania provides an example of how implementation is shaped by practice. Companies applying for authorisation must demonstrate that their transitional CBAM quarterly reports precisely match their customs declarations. Reported quantities are expected to align with customs data.

For companies relying heavily on ERP systems, small discrepancies between internal data and customs declarations can occur. Romania’s approach underlines an important principle: CBAM reporting must reflect customs reality. CBAM does not operate alongside customs. It operates on top of it.

Austria: integration with EU ETS systems

In Austria, access to the CBAM portal requires companies to navigate via the EU ETS access module. For importers not subject to the EU Emissions Trading System, this can be unexpected. From an administrative perspective, authorities build on existing systems. For companies, however, this illustrates how CBAM becomes embedded within national infrastructures that may not be obvious from the regulation itself.

The Netherlands: authentication through a private system

In the Netherlands, access to the CBAM registry requires authentication via eHerkenning, a privatised digital identification system. Companies must select an approved provider, obtain the correct access level, and manage associated fees.

Unlike many Member States where access is handled directly by public authorities, the Dutch model introduces a market element into what is often perceived as a purely administrative process. For importers, access depends not only on compliance readiness but also on navigating the national authentication framework.

Belgium: broader digital role authorisations

Belgium applies role-based authorisation. The role required for CBAM access may also grant access to additional functionalities within the customs system. This reflects how CBAM has been integrated into an existing digital environment. For companies working with service providers, this raises governance questions around access management and internal control.

When interpretation evolves

As with many new regulatory frameworks, interpretation evolves over time. In Belgium, previously confirmed procedural approaches were later reconsidered by the competent authority. Written confirmations had to be revisited. Applications were revised and, in some cases, resubmitted.

Such developments are not unusual in early implementation phases. They underline the importance of staying aligned with both European rules and national administrative practice.

Navigating CBAM across Member States

CBAM may be a single European mechanism, but it operates through multiple national gateways. The differences are subtle yet impactful. They shape how companies apply for authorisation, reconcile data, access registries, and structure internal processes. For businesses with cross-border exposure, or those preparing for the definitive CBAM phase in 2026, understanding these national layers is essential.

Together with Dubrink, Pincvision supports companies across the EU in managing CBAM in a structured and scalable way. By combining customs expertise with digital reporting and automation solutions, we help organisations navigate both the European framework and the national realities behind it.

If you are assessing your CBAM readiness or preparing for the next phase, we are happy to support you.

This article was written by Marcel Duits, Chief CBAM Officer at our partner Dubrink, a specialist in CBAM compliance.