Getting started with the CBAM
It is recommended to start working on the new international environmental rules in time. But how? And where do you start? Our Sustainable Tax team is happy to take you through the first steps of the transition period, so that you will be prepared in time for the final implementation starting in 2026 and the corresponding levies.
Research which goods are subjected to the new rules
Are you importing goods from outside the EU? And do you estimate that these have a high carbon impact? If so, they may come under the new rules, and must be identified as CBAM goods. Ask the following questions:
- What is the origin of these goods?
- What is the volume per shipment of these goods?
- Who are the producers of the imported goods?
- Are the products included in the Combined Nomenclature (CN) codes listed in the annex to the CBAM regulation?
Develop a proper administration system for this new levy
As an importer, you are responsible for obtaining the correct information on the carbon emissions of the goods you import, and for its administration and reporting. This requires a good system that you integrate into your existing business processes.
- Integrate an administration system into your existing business processes and maintain it (as changes are likely to occur).
- Make sure your company's internal control procedures are ready for this new levy to ensure compliance.
Find out what information you need to gather from your foreign supplier/producer
What information and data are needed to calculate the correct carbon emissions for your CBAM goods? And then, ultimately, to comply with the reporting obligation? For this, you do the following:
- Do you buy directly from a producer outside Europe? If so, ask the manufacturer directly for the required information.
- Do you not buy directly from the manufacturer? Let your foreign supplier gather the information. After all, this party has to provide you with the information to submit the report. For this purpose, manuals and Excel sheets have been made available by the EU to help your supplier/producer in this process.
Register your organisation as a CBAM declaring company
To import goods from outside Europe and comply with the new environmental tax, it is necessary to register your organisation as a CBAM declaring company.
- Register your organisation as a CBAM declaring company in the portal.
- Establish a plan for submitting CBAM reports.
- Implement controls to ensure that you meet the requirements.
Looking to the future
The CBAM will continue to evolve. Consider the possible extension of the levy to other types of goods and sectors and changes in the calculated carbon emissions. Furthermore, we see that an increasing number of countries are following the example of the European Union with more or less similar regulations. Similar legislation is also planned in the United Kingdom from 2027. Regulations are also being prepared in the United States, Australia and several Latin American countries. It demonstrates that pricing carbon emissions from goods is a global development.
As such, it is a development that impacts your company as well. Incidentally, this can also be to your advantage: you only pay the CBAM on carbon emissions that are not taxed abroad. In that respect, foreign levies reduce the CBAM levy you have to pay in the EU.
It is crucial that you monitor these developments closely and adapt your strategies to comply with regulations and maintain a competitive advantage. If you start working quickly, you can even get ahead of competing companies. After all, with the new environmental rules, you are doing business in a much more environmentally friendly way; your ecological footprint will be reduced, your competitiveness in the market will improve and new market opportunities may present themselves.
Grant Thornton: your trusted CBAM partner
Grant Thornton's Sustainable Tax team is working on new sustainability laws and regulations on a daily basis. We have built up in-depth knowledge and global experience
How can we help you?
Our Sustainable Tax team recognises that aligning with sustainability goals can disrupt your usual business operations. We are adept at helping companies integrate ESG (Environmental, Social, and Governance) principles with "green" tax compliance, strategy and opportunities. Our goal is not only to help you comply with ever-changing regulations, such as the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), but also to ensure that your company makes a meaningful impact with regard to corporate social responsibility.
Our one-stop-shop approach addresses several challenges. From navigating complex reporting requirements to managing the implications of the Carbon Border Adjustment Mechanism (CBAM) and ensuring compliance with the EU's Deforestation Regulation (EUDR). In addition to compliance, we excel in optimising tax benefits through strategic investments in sustainable assets and initiatives.
We understand that embracing sustainable development goals may mean a shift from your traditional business practices. Let us guide you through this journey, creating a tax strategy that not only complies with regulations, but also fits seamlessly with your commitment to sustainability.
Together, let's pave the way for a sustainable and tax-efficient future for your business.
Contact us
We would be happy to help your company to comply with the Carbon Border Adjustment Mechanism (CBAM). Read more about our services on our website or contact our Sustainable Tax specialists.
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