Carbon Border
Adjustment Mechanism

What is the CBAM?

CBAM is a price adjustment applied to imports into the EU for designated goods based on their CO2 emissions in the production process outside the EU.

What are the key characteristics?

Precise Carbon Assessment

CBAM looks at the actual carbon content of imported goods instead of applying broad measures to entire countries.

Individual Company Evaluation

Companies are reviewed based on specific factors, including the carbon content of their imports, EU Emissions Trading System (EU ETS) allowances, and carbon pricing in the country where the goods are made.

Possible Exemptions

Some companies may not have to follow CBAM rules, especially if they're already part of the EU ETS system

Certification and Compliance

Under CBAM, companies must buy and use certificates in their yearly reports to offset the carbon emissions linked to their imported products.


What are the main concepts
behind CBAM?
Equitable Carbon Pricing

EU-based businesses are subject to a carbon price for their operations within the EU. Imported goods are required to undergo a carbon adjustment, equivalent to the cost they would have incurred if they had been manufactured following the EU's carbon pricing regulations, specifically the Emissions Trading System (ETS).The CBAM fee is modified to reflect the extent of free allowances allocated to EU production within the industries under consideration.

Preventing Double Charges

To prevent double carbon pricing, if a non-EU producer can demonstrate that they have already paid a carbon price for the production of the imported goods in a third country, this amount can be subtracted from the obligations of the EU importer.



The "reporting declarant" is the entity responsible for reporting emissions of imported goods. Typically, it's the "Importer," but other options exist based on who submits the customs declaration. Each ton of imported goods falls under the responsibility of one reporting declarant, ensuring no double reporting or omissions.


According to the Union Customs Code (UCC), the reporting declarant can be:
- The importer making a customs declaration.
- A person authorized to declare imports under Article 182(1) of the UCC.
- An indirect customs representative, under Article 18 of the - UCC, when the importer is outside the Union or as agreed under Article 32 of the CBAM Regulation.


What sectors and related products
are in the scope of CBAM?

Each sector to be represented in 6 different sections


Iron & Steel





CBAM includes in its scope certain precursors and downstream products.

The selection process for inclusion is guided by the following primary criteria: High Risk of Carbon Leakage and Significant Coverage of CO2 Emissions. In a subsequent phase, the scope of inclusion may be expanded to encompass additional sectors



The implementation of CBAM is divided into two parts with a mechanism review between the two:

- Transitional Phase (Oct 2023 – Dec 2025)
- Review 2025: Scope Extension, Emission revision, Exports
- Post Transitional/Definitive Phase (Jan 2026 onwards)


How are the obligations of the reporting declarant envisaged in the two phases of CBAM?
Transitional Phase (Oct 2023 – Dec 2025) – Monitoring and Reporting obligations

CBAM report containing: Total quantity of goods imported during the preceding quarter; total embedded direct and indirect emissions in those goods; the carbon price due in the country of origin for the embedded emissions; report to be submitted each quarter

CBAM declaration containing the following

Total quantity of goods imported during the preceding calendar year; total embedded emissions in those goods Emissions to be verified by EU accredited verifier; total number of CBAM certificated to be surrendered; the carbon price effectively paid in the country of origin for the embedded emissions declaration to be submitted each year


In what cases may penalties be aplied?

Penalty Application:

- When the reporting declarant fails to submit a CBAM report.

- When an incorrect or incomplete CBAM report is submitted, and the reporting declarant doesn't take corrective actions when initiated by the competent authority.


What are the exemptions from CBAM application?

CBAM shall not apply to:

-Goods for which the Carbon Price was paid in originating third country in the form of tax, levy, fee or under the ETS system (NO DOUBLE PRICING)

- Goods imported in the customs territory which do not exceed EUR 150 per consignment (DE MINIMIS RULE)

- Goods contained in the personal luggage of travellers coming from a third country and that do not exceed EUR 150 (DE MINIMIS RULE)


How can ECONOS assist you?

Consultancy for importers:

- Assistance in understanding CBAM Mechanism

- Assistance in gathering relevant data to complete CBAM Report

- Assistance in completing CBAM Report

Contact us

Consultancy for third country producers:

- Assistance in understanding CBAM Mechanism

- Assistance in calculating CO2 emissions

- Assistance in completing CBAM template for information provision for importers

Contact us