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Reporting Requirements for CBAM and Consequences of Non-Compliance

  • The transition period for the Carbon Border Adjustment Mechanism (CBAM) began on October 1st.
  • If you imported regulated products such as cement, fertilizers, aluminum, hydrogen, electricity, iron/steel during the last quarter of 2023, you may be required to submit the first quarterly CBAM report before January 31st, 2024.
  • The report must be submitted through the CBAM portal, selecting the “Customs” option.
  • The report should include information such as the quantity of imported goods, the 8-digit tariff code, direct and indirect greenhouse gas emissions, and supplier and facility data.
  • Failure to submit the quarterly MAFC report may result in fines ranging from €10 to €50 per ton of unreported emissions.
  • Starting in January 2026, only authorized declarants will be able to import goods into the EU customs territory for CBAM purposes.
  • To become an authorized declarant, applicants must not have serious or repeated violations of customs, tax, market abuse, or CBAM regulations.
  • If you believe you may be affected by CBAM, we can assist you.


Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.


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