On January 1, 2026, the European Union’s Carbon Border Adjustment Mechanism (CBAM) officially entered its definitive phase. This marks the end of the transitional period and the beginning of financial obligations for importing companies.
Which products are affected?
The regulation applies to the importation of carbon-intensive goods: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen.
Requirements & Procedures: Authorised Declarant Status
From now on, it is mandatory to hold the status of Authorised CBAM Declarant to import these goods into the EU customs territory.
-How to apply: Registration must be completed via the CBAM Registry through your National Competent Authority.
-Verification: Declared emissions must now be audited and verified by an accredited independent third party.
New Deadlines and Tax Obligations
The shift to the definitive phase transforms reporting duties into financial and annual obligations:
-Annual Declaration: Quarterly reports are abolished. Moving forward, a single annual declaration is required. The first one (covering 2026 imports) must be submitted no later than September 30, 2027.
-Purchase of Certificates: Starting in 2027, importers must purchase and surrender “CBAM Certificates” equivalent to the CO2 emissions generated during the manufacturing of the goods imported in 2026. The price of these certificates will be linked to the EU Emissions Trading System (EU ETS).
-Exemption (De minimis): Imports of less than 50 tonnes per year are exempt from these obligations (except for electricity and hydrogen, which have no minimum threshold).
Specialised advice from Feliu N&I
At Feliu N&I, we support companies importing products subject to CBAM in understanding and adapting to this new European regulatory framework. Our team provides guidance on interpreting the regulation and helps identify the obligations that may affect each company, as well as advising on the steps required to comply with these new requirements. Among other matters, we offer advice on aspects such as obtaining the Authorised CBAM Declarant status, registration in the CBAM Registry, obligations related to the annual declaration, and issues linked to the acquisition of CBAM certificates. In this way, we help companies anticipate these regulatory changes and manage their import operations with greater certainty.
