We’d like to share an update on the Carbon Border Adjustment Mechanism (CBAM). We are still in the transitional phase, but this will end by late 2025.
👉 As of 1 January 2026, the definitive period will begin.
What will change for you?
- Importers bringing in more than 50 tons of CBAM goods per year (such as iron and steel, cement, fertilizers, aluminum, hydrogen, and electricity) will be required to register as an authorized CBAM declarant starting in 2026.
- Without this status, imports may be refused and fines can be imposed.
- Even when you appoint an indirect customs representative, they are subject to the same obligations.
Action required before the end of September 2025!
- Apply for your status as an authorized CBAM declarant in time.
- Keep in mind that the Belgian National Competent Authority (BE NCA) may request additional documents.
- If you appoint an indirect customs representative, be sure to inform the BE NCA as soon as possible.
Obligations as of 2026
As an importer (or through your representative), you are responsible for:
- Reporting the embedded emissions.
- Purchasing CBAM certificates.
- Complying with all CBAM obligations.
Practical steps
- The first reporting will only be required in 2027 (likely by May) and will cover imports from 2026.
- At that time, the purchased CBAM certificates must also be submitted.
- The price of certificates will be calculated based on the average auction price of EU ETS allowances (€/ton CO₂).
- Have you already paid emission allowances in the country of production? Then this amount can be deducted from the CBAM certificates to be purchased.
Note: the reporting covers your 2026 imports, while certificates only need to be purchased in 2027. This means the price may differ between the period of import and the actual purchase. It is therefore important to make timely arrangements with your customers and partners.
We are still waiting for the final regulation, but the outlines are already clear. At DKM Customs, we closely monitor these developments and are happy to guide you every step of the way: from registration to reporting and certificate management.
Any questions or need guidance? Feel free to contact us.
