The operation of the CBAM
Entrepreneurs who import goods from outside the EU will be paying a levy for the carbon emissions created by the production of those goods. From 2026, entrepreneurs will be obliged to cover these emissions by so-called CBAM certificates. One certificate equals one tonne of carbon emissions. Obviously, as a company has to buy these certificates, the price of imported goods from outside the EU will increase. The EU supplier is likely to pass on the CBAM costs to the customer. Ultimately, the aim is for producers to produce in a more environmentally friendly way, thereby reducing global carbon emissions.
The challenges for your business are listed below
Calculating and reporting carbon emissions
How do you know what emissions are involved in the goods your company imports? Data quality is the big challenge, and it is your responsibility to check this quality. To this end, you should set up a data collection and verification process. This does not have to involve a complicated and expensive calculation module, but your data must be accurately collected and comparable. From 1 January 2026, data must be verified by an external independent party.
Anticipating phased implementation
The rules will not be imposed all at once. This will be done in phases. Moreover, it is possible that during the implementation of the rules, matters such as the product group and the calculation method of carbon emissions will still be adjusted. So the costs and compliance requirements remain uncertain for quite some time. That demands a lot from your business. How do you assess the impact of the new levy on your business and supply chain? And how do you take into account factors such as product classification, emission intensity and market dynamics?
Dealing with existing trade agreements and new disputes
Of course, the introduction of the CBAM on an international scale may affect existing trade agreements. It is also possible that the new rules could lead to trade disputes. How do you deal with this?
In the face of these challenges, it may be useful to seek specialist support and advice. This way, you ensure compliance and reduce the risks associated with the implementation of the CBAM. Our Sustainable Tax team will be happy to assist you with this.