Carbon adjustment at the border on EU imports (CBAM)

Do you import goods from outside the EU? Your import may be covered by the rules set in the Carbon Border Adjustment Mechanism (CBAM) Regulation. If this is the case, you may have to report these goods.

Which goods are covered by CBAM

CBAM applies to imports of goods in the categories:

• iron and steel
• cement
• fertilisers
• aluminium
• electricity
• hydrogen

You can tell whether a product is covered by CBAM by its CN code. You can see the full list of CBAM goods and CN codes in Annex I of the CBAM regulation. If these goods were produced outside the European Economic Area (EEA) or Switzerland and imported into the EU, they are covered by this rule.

You must comply with CBAM if you import more than 50 tonnes of CBAM goods per year. Do you import hydrogen or electricity? Then CBAM always applies to you, even if you import less than 50 tonnes.

Who needs to report?

The CBAM declarant must submit the CBAM report. In many cases, the importer is the CBAM declarant. Are you using indirect customs representation? Then the indirect customs representative or the importer may file the CBAM report. If you are established outside the EU, the indirect representative is always the CBAM declarant.

What do you need to report ?

You must report:

• who the CBAM declarant is and their role in the import process
• which goods you imported and which customs procedures you followed in doing so
• where the goods came from and in which production facility they were made

You must also report emissions released from production. You can choose to report the default values for this, or to report the actual emissions. If you choose to enter the actual emissions in your report you must request certain information from the manufacturer of the goods about the products you are importing. You request for:

• the embedded direct and indirect emissions
• the specific characteristics of the products
• the carbon price paid in the country of production

Embedded emissions are the emissions from fuels and raw materials released in the production process. This includes emissions from the generation of heat and electricity consumed in the production process.

The European Commission has published a Guidance document and a communication template to help you request this data.

Read more about preparing and submitting a CBAM report at the EU’s website or the Dutch Emissions Authority’s website (Nederlandse Emissieautoriteit, Nea, in Dutch).

When to report?

Are you the importer or the importer’s authorised representative? Then you must report each quarter how much CO2 was emitted in the production of the CBAM goods you imported in that quarter. Did you not import any CBAM goods in a quarter or did you import less than 50 tonnes mass? Then you do not need to submit a report. If you import hydrogen or electricity, you must always submit a report, even if you imported less than 50 tonnes mass.

You report via the European Commission's CBAM register. You need eHerkenning to log in. Webinars explaining how to login and use the CBAM register are available on Customs & Tax EU Learning Portal.

Applying for authorisation

From 2026, you or your indirect customs representative will have to apply for prior authorisation to import CBAM goods. You can apply for admission as a CBAM declarant in the application module of the European CBAM register. To do so, you will need eHerkenning level 3.

If you want to import more than 50 tonnes CBAM goods, or hydrogen or electricity in 2026, then you must apply for authorisation as soon as possible.