Updates on the EU Carbon Border Adjustment Mechanism (CBAM)

Empowering Sustainable Trade: An Increasingly Crucial Role of Data Management in Compliance
November 9, 2023

The European Union (EU) has taken a significant step in its commitment to combat climate change by implementing the Carbon Border Adjustment Mechanism (CBAM) starting from October 1, 2023. This mechanism is designed to address the issue of carbon-intensive production being moved abroad to take advantage of lower environmental standards, or the replacement of EU products with imports that have higher carbon dioxide emissions. In this article, we will delve into the details of CBAM, including its objectives, implementation phases, and reporting requirements.

What is the EU Carbon Border Adjustment Mechanism (CBAM)?

CBAM is a regulatory instrument introduced by the European Union to tackle the problem of carbon leakage. Carbon leakage refers to the phenomenon where industries with high carbon emissions move their production to countries with lower environmental standards, effectively exporting their emissions. To address this issue, CBAM places a carbon tax on certain imports from non-EU countries, encouraging environmentally responsible production practices globally.

Phases of CBAM Implementation

Transitional Period (October 1, 2023, to December 31, 2025)

During the first phase of CBAM implementation, which spans from October 1, 2023, to December 31, 2025, importers of specific goods are not required to make any payments or financial adjustments. However, they must fulfill reporting obligations by submitting quarterly reports. These reports should contain details related to the imported goods and the emissions associated with them.

Reporting Deadline

The first CBAM report must be submitted by January 31, 2024, covering the final quarter of 2023. Failure to submit reports may result in penalties.

Reported Information

The required information includes the quantity of imported goods, their CN code, the country of origin, the production facility, production routes, specific embedded direct emissions, and sector-specific parameters.

Calculation Methods

Regulation 2023/1773 outlines two target calculation methods based on accurate analyses and data from measurement systems. However, by the end of December 2024, other methods that provide similar accuracy may also be used. Until July 31, 2024, importers who cannot gather all necessary information may use default values provided by the Commission for the transitional period.

Tools and Resources for Compliance

The European Commission has developed essential tools and resources to facilitate compliance with CBAM requirements:

  • CBAM Transitional Registry: Accessible via the Trader Portal, this registry serves as a central hub for importers to manage their CBAM-related activities.
  • Guidances: The Commission provides comprehensive guidance documents to assist importers in understanding and complying with CBAM regulations. There is a guidance document for importers into the EU, and one for operators outside the EU.
  • Communication Template: Importers can utilize this template to collect information about their production processes and perform the necessary calculations to meet CBAM reporting requirements. Download the communication template here

Full Implementation of CBAM

Full implementation of CBAM is scheduled to begin on January 1, 2026. At this point, importers will be required to obtain the status of an authorized CBAM declarant, purchase and redeem certificates as a form of carbon tax payment, and submit annual reports. This phase represents a more comprehensive and financially impactful stage of CBAM enforcement.


The EU Carbon Border Adjustment Mechanism (CBAM) is a pivotal step in the EU's commitment to reducing carbon emissions on a global scale. By imposing carbon taxes on certain imports and promoting transparency through reporting, CBAM aims to create a level playing field for industries worldwide. Importers and businesses operating in affected sectors should stay informed about CBAM regulations and take proactive steps to ensure compliance during the transitional period and beyond. As the world continues to address climate change, CBAM stands as a noteworthy effort to mitigate carbon leakage and promote sustainable production practices.



How can we help?

CATTS' trade compliance professionals can support in carrying out an initial CBAM impact assessment and broader supply chain impact reviews in the light of the CBAM regulations, implementation, transitional period and compliance requirements. Furthermore, our EPOS™ platform grants you the full visibility and access to your trade data necessary for identifying and assessing the carbon footprint of imported goods, a fundamental aspect of CBAM.

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