The timeline

May 2023

Introduction of the Carbon Border Adjustment Mechanism

The EU legislation has been published and companies, the EU and regulators are getting ready to gain experience with the new scheme and the system behind it in order to correctly calculate and pay the correct levy over time.

October 2023 to 1 January 2026

Transitional phase with reporting obligation

From this time onwards, your company is required to prepare a quarterly report detailing the goods imported from outside Europe and the carbon emissions involved. If you don't import anything in a quarter, you don't have to report either. During this period, you prepare your operations for the final CBAM rules.

Third quarter 2024

First report based on actual values

The first report to be drawn up is for the third quarter of 2024, and must contain the actual values of carbon emissions from your imports from outside the EU.

Please note! (Software) problems

Currently, many companies are still experiencing difficulties submitting the report. As a company, you use E-recognition to submit your reporting in the EU's portal At the moment, for example, complications are still arising if you authorise another company in the chain to submit reports for your trade flows. Entrepreneurs are also experiencing problems due to the portal being very busy.

Furthermore, information from foreign suppliers regarding the carbon emissions of goods does not yet seem to be of sufficient quality. For this reason, companies could still rely on and use the European Commission's default values until the end of the second quarter of 2024.

Mid 2025: register as a CBAM declaring company

From 2025, it will be possible to get your organisation registered as a CBAM declaring company for the final system that comes into force in 2026. That means you can import goods from outside the EU. To this end, your organisation makes an application to the Netherlands Emissions Authority (NEa), which will check the following:

  • Does your organisation have the financial and operational capacity to meet CBAM obligations upon importation?
  • Is the company not in arrears with its tax payments?
  • Has the company not repeatedly breached customs laws, tax regulations or rules on market abuse?
  • Does the organisation not have any criminal records in respect of serious

If your organisation is not registered, it cannot import goods.

From January 2026: obligation to purchase CBAM certificates

From 2026, your company will be required to purchase CBAM certificates. By doing so, you offset the carbon emissions caused by the production of the goods you import from outside Europe. One certificate equals one tonne of carbon emissions. Every year, your organisation declares the embedded CO₂ emissions from imports and purchases (sufficient) CBAM certificates for this purpose.

Sign up for our Newsletter

Sign up for our newsletter and receive new insights on finance, business operations and strategy.

Please note! Fines

If you fail to comply with this obligation; If you do not buy certificates, but are importing goods from outside the EU; The NEa may impose a fine. Initially, this will be up to 450,000 euros per offence. If your annual turnover is more than EUR 4.5 million, the fine could be up to 10% of that turnover. During the transition phase, strict enforcement is not yet in place. If you make mistakes, the NEa will start a correction procedure to supplement the report.