CBAM Importer Obligations (2026)
The EU CBAM transitional period began on October 1, 2023, requiring importers to report the embedded emissions in imported goods covered by CBAM (steel.
What Happened
The EU CBAM transitional period began on October 1, 2023, requiring importers to report the embedded emissions in imported goods covered by CBAM (steel, aluminum, cement, fertilizers, electricity, hydrogen). From January 2024, importers faced quarterly reporting deadlines with detailed emissions data requirements. Many cross-border sellers importing steel and aluminum products into the EU were unprepared for these new reporting obligations. Failure to report triggered warning letters from national customs authorities, and beginning 2026, importers will need to purchase CBAM certificates to cover embedded emissions, adding direct costs.
October 2023 (transitional phase), full implementation 2026
Cross-border importers of CBAM-covered goods (steel, aluminum) were unaware of new reporting obligations during the transitional phase.
Resolution
- 1Determine if your imported products fall under CBAM categories (CN codes in Annex I)
- 2Register in the CBAM Transitional Registry as an importer
- 3Collect embedded emissions data from non-EU suppliers
- 4Submit quarterly CBAM reports to national customs authority
- 5Prepare for 2026 full implementation by budgeting for CBAM certificate purchases
Confirm timing with the operator or competent authority 1-2 weeks
ask the operator for the current rate; this page does not invent a range
Lessons Learned
- •CBAM is a new EU trade measure that adds compliance obligations for carbon-intensive imports
- •The transitional phase is a reporting-only period, but 2026+ requires purchasing certificates
- •Cross-border sellers of steel, aluminum, and other covered goods must track embedded emissions
- •Non-EU suppliers must provide emissions data - this affects supply chain relationships
Prevention
- ✓Identify all CBAM-covered products in your import portfolio using EU CN code classifications
- ✓Establish emissions data collection processes with non-EU suppliers
- ✓Engage a customs broker or compliance consultant experienced in CBAM reporting
- ✓Monitor European Commission CBAM guidance updates and delegated acts for implementation details