The European Carbon Border Adjustment Mechanism (CBAM) introduces a new regulatory framework designed to address the carbon footprint of imported goods. As CBAM rolls out in stages, businesses will need to adapt to its requirements to ensure compliance and avoid disruptions in trade.
Transition Period: Reporting Requirements Until 2026
From now until the end of 2025, CBAM operates in a transition phase, requiring quarterly reporting of emissions linked to imported goods. This allows companies time to prepare for the stricter obligations starting January 1, 2026.
Obligations from January 2026
As of January 1, 2026, importers will face several new requirements, including:
- Obtaining prior authorization as a CBAM declarant.
- Ensuring sufficient CBAM certificates in their account each quarter.
- Submitting an annual verified declaration detailing actual CO₂ emissions from the production of imported CBAM goods.
- Paying for emissions using CBAM certificates
Key Updates on CBAM Implementation
1. Authorization for CBAM Declarants
To import CBAM-regulated goods into the EU from January 2026, businesses must be authorized as CBAM declarants. The Dutch Emissions Authority (NEa) advises companies in the Netherlands to apply for authorization through the new CBAM register, which will be available in January 2025. However, the NEa recommends waiting until April 2025 to submit applications, allowing time for potential issues in the register to be resolved.
To ensure timely authorization:
- Submit complete applications between April 1 and August 31, 2025 to guarantee a decision before January 1, 2026.
- Late submissions after September 1, 2025, risk delays, potentially preventing imports in early 2026.
2. Higher Participation Threshold Advocated by NEa
The NEa has called on the Dutch government to advocate for a higher participation threshold in the CBAM framework. The current €150 threshold imposes significant compliance burdens on smaller importers, despite their limited emissions impact. Raising the threshold would alleviate these challenges and improve feasibility for businesses and regulators alike.
3. Reporting Q4 2024 Data
Companies can now submit CBAM reports for the fourth quarter of 2024. These must be completed by January 31, 2025. Provisional reports are allowed if all data isn’t available, with corrections accepted until March 31, 2025.
4. Technical Updates to the CBAM Register
The European Commission continues refining the CBAM register. Notable updates include:
- Producers outside the EU can submit emission data directly to the Commission from January 2025.
- Updated user guides and technical tools (XSD/XML) are now available for stakeholders.
