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Preparing for CBAM: New Importer Obligations Starting 2026

  • New Obligations for CBAM Importers: Starting in 2026, entities importing goods subject to the Carbon Border Adjustment Mechanism (CBAM) must obtain the status of an authorized notifier. The application process for this status began on 1 December 2025, requiring importers to prepare for compliance in advance.
  • Registration Process: Importers can apply for authorized CBAM status electronically through the EU CBAM portal, with the Director of the Tax Administration Chamber in Poznań overseeing the applications. Importers may continue to import CBAM goods before receiving their status if they submit their application by 31 March 2026.
  • Exemptions and Transition Period: Small importers importing less than 50 tonnes of CBAM goods annually are exempt from obtaining authorized notifier status, except for electricity and hydrogen imports, which require registration regardless of quantity. Importers are currently in a transitional phase focused on data collection and preparation for full implementation, emphasizing the importance of timely registration and compliance.

Source Deloitte

 



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