Carbon adjustment at the border on EU imports (CBAM)

Published by:
Netherlands Enterprise Agency, RVO
Netherlands Enterprise Agency, RVO

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.

Do you import a shipment of CBAM goods worth up to €150? Then you do not have to report.

Who needs to report?

In many cases, the importer is the CBAM declarant. And therefore the person who must submit the CBAM report. 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 request information from the manufacturer of the goods about the products you are importing. You report on:

  • the embedded 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 (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 CBAM goods worth €150 or less? Then you do not need to submit a report.

Reminder: From 2026, you will have to apply for prior authorisation to import these goods. Then you may also have to start paying for the CO2 emitted during their production. You will then report annually, instead of quarterly.

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.

This article is related to:

Questions relating to this article?