CBAM – changes and new obligations in CO₂ emission reporting

We kindly remind you that the CBAM transition period is coming to an end. This is an important moment to prepare for new environmental reporting obligations. We encourage you to read the information below, which outlines the key requirements and the forms of support offered by Forvis Mazars.

CBAM (Carbon Border Adjustment Mechanism), a mechanism for adjusting prices at borders to take into account CO₂ emissions, is a new climate policy tool of the European Union. Its aim is to equalize the costs of emissions between products manufactured in the EU (covered by the EU ETS) and those imported from outside the EU, originating from countries with less restrictive environmental regulations.

CBAM is being implemented gradually, with its first stage (the so-called transition period) beginning October 1, 2023, and will last until the end of December 2025. Currently, importers and their customs representatives are required to submit quarterly reports on the actual emission values contained in imported products covered by CBAM (such as cement, cast iron and steel, aluminum, fertilizers, hydrogen, and electricity). Until 2026, reports must be submitted by the 31st day of the month following the end of each quarter via the EU's CBAM transitional registry.

After the transition phase ends, i.e. from January 1, 2026, the final stage will come into force, imposing additional obligations on importers. Entrepreneurs will be required to submit annual CBAM declarations containing data on the volumes of imported goods and related embedded emissions. In addition, it will be necessary to purchase and redeem CBAM certificates, the price of which will reflect the current value of emission allowances in the EU ETS. In order to fulfill these obligations, it will be necessary to obtain the status of an authorized CBAM declarant in advance. Applications for this status should be submitted already in 2025.

Due to the complexity of reporting requirements and the growing administrative obligations associated with CBAM, we offer comprehensive support in the implementation process and in ensuring compliance with regulations.

How can we help?

To effectively implement and comply with CBAM requirements, we propose the following approach:

Phase 1: CBAM implementation

We assist in determining the scope of CBAM application in your company, analyze products and the supply chain and collect the emissions data necessary for reporting.