The Carbon Border Adjustment Mechanism (CBAM): What importers need to know

What is carbon leakage?

The Commission notes that climate change is a global problem that needs global solutions. When the EU raises its own climate ambition while less stringent climate policies remain in other parts of the world, there is a risk of carbon leakage.

According to the Commission, carbon leakage occurs when:

• companies based in the EU move carbon-intensive production abroad to jurisdictions with less strict climate policies, or

• EU products are replaced in the EU market by more carbon-intensive imports.

How does CBAM address carbon leakage?

• CBAM is described as a system to confirm that a carbon price has been paid for the embedded carbon emissions generated in the production of certain goods imported into the EU. Aligning the carbon cost for imports with that of goods produced under the EU Emissions Trading System (EU ETS) supports the EU’s objective of reducing the risk of carbon leakage while maintaining its climate ambition.

From 2026, CBAM moves into its definitive regime. The Commission describes the key features as follows:

• Registration: EU importers of CBAM goods register with national authorities, which are responsible for granting access to and oversight of the system.

• CBAM certificates: Importers buy CBAM certificates from national authorities. The price of these certificates is calculated from the weekly average auction price of EU ETS allowances, expressed in euro per tonne of CO₂ emitted.

• Annual declaration: Importers declare the emissions embedded in their imports and surrender a corresponding number of CBAM certificates each year.

• Carbon price paid in the country of origin: If importers can prove that a carbon price has already been paid during production in the country of origin, the corresponding amount can be deducted from the number of certificates they must surrender.

A review of CBAM’s functioning during the transitional phase will be completed before the definitive system enters into force. At the same time, the product scope will be reviewed to assess the feasibility of including other goods produced in sectors covered by the EU ETS, including certain downstream products and other candidates identified during negotiations. The review report will include a timetable to set out their possible inclusion by 2030.

CBAM focuses on greenhouse gas (GHG) emissions embedded in imported goods - that is, the emissions generated in the production process of those goods.

During the transitional phase:

• Importers must report both direct and indirect emissions embedded in their imports. 

• The Commission indicates that indirect emissions will be included after the transitional period for some sectors (cement and fertilisers), based on a methodology set out in an Implementing Regulation. 

Electricity produced in the EU exclusive economic zone (EEZ)

The Commission clarifies that CBAM does not apply to electricity generated in the exclusive economic zone (EEZ) of EU Member States and imported into the EU. This electricity is considered to have “EU origin” and is therefore:

• not covered by the relevant CBAM article,

• not subject to reporting obligations during the transitional period, and

• not subject to CBAM adjustments from 2026.

In this context, the Commission notes that there is no obligation for such electricity imports to apply for authorised CBAM declarant status or to access the CBAM Registry.

How does CBAM work for importers in practice?

What is the CBAM Registry and who are CBAM declarants?

The Commission refers to a CBAM Registry, which is the digital system through which:

• importers (and their representatives) submit CBAM reports during the transitional phase; and

• since early 2025, CBAM declarants can apply for the status of “authorised CBAM declarant”

Since 1 January 2025, a dedicated portal section of the CBAM Registry allows installation operators outside the EU to upload and share installations and emissions data with reporting declarants, rather than sending the same information to multiple parties.

According to the CBAM page:

• Applications for authorised CBAM declarant status are processed by the National Competent Authority (NCA) of the EU Member State where the applicant is established.

• This status will become mandatory from 1 January 2026 for imports of CBAM goods into the EU customs territory.

Role of National Competent Authorities (NCAs)

The Commission publishes a provisional list of National Competent Authorities (NCAs) for CBAM. It states that access to the transitional CBAM Registry should be requested through the NCA of the EU country where the importer is established.

NCAs are therefore the main contact point for importers needing access to the registry and procedures related to authorised CBAM declarant status.

At Röhlig Logistics, we support our customers by ensuring transparent, compliant and efficient freight management in line with evolving sustainability regulations. Through our global network and Digital Services & Tools, Röhlig can help importers and exporters navigate customs reporting requirements, manage documentation flows, and align transport processes with the latest EU environmental and trade frameworks. For the most up-to-date information on CBAM, please refer to the European Commission’s “Carbon Border Adjustment Mechanism” web page.