The Carbon Border Adjustment Mechanism (CBAM) is designed to harmonise carbon costs between imported and domestically produced goods within the EU. As of now, this mechanism consists of submitting, on a quartely basis, CBAM reports to the EU Commission and, starting in 2026, payments will be required in the form of CBAM certificates. If importers wish to continue to trade within the E.U., it is essential for them to comply with this new regulation.
What is the timeline?
Transitional phase
2023-2025
Identifying the type & quantity
of goods affected
Gathering, compilation, and verification of CO2 emission values.
Definitive phase
From 2026 onwards
"Authorised CBAM declarant" Accredition
As of January 1, 2026, only authorised declarants can import CBAM goods into the EU.
Payments under the form of CBAM certificates
CBAM Declarants are financially accountable and need to purchase and submit the required CBAM certificates related to the CO2 emissions filed.
Annualy filing
The CBAM reporting period shifts from quarterly filings to an annual filing.
Certification of CO2 values by an accredited verifier
CBAM declarants will need to ensure that their CO2 emission values are validated by an accredited verifier
Obtaining CBAM certificates related to expected CO2 emissions
It will be necessary to have CBAM certificates in advance equivalent to the CO2 emissions of the products intended to be imported in the following year
Minimum stock of CBAM certificates
At the end of each quarter, declarants must maintain a minimum stock of CBAM certificates
Reporting steps
Identifying the
products affected
by CBAM
Engaging with
your suppliers to gather CO2 emission values
Preparing the CBAM report
with the help of the
CBAM Navigator
Submission of
the CBAM report onto the official EU portal
1/ Identifying the CBAM goods
In order to know if your goods are concerned by the CBAM you need to be aware of the origin of the product and its HS code.
Each good is assigned a unique HS code based on its characteristics. This code helps determine if a good falls under the CBAM category and, therefore, if it's subject to the carbon emissions reporting and future levy.
2/ Engaging with your suppliers
For the filing of your CBAM report, you will need to declare the amount of CO2 emitted by the production of the concerned raw materials.
In order to obtain this information you will most likely have to contact your supplier/ the producer so that they can provide you with this data.
For the first three CBAM reports default values published by the EU commission were accepted but since July 2024 actual CO2 values are required.
Obtaining accurate CO2 emission values from your suppliers can be a complex task.
3/ Preparing for the report
The first step to submitting the MACF report is to register on the European Commission platform. Once access is granted, you can manually complete your report by providing the required information.
However, this option requires a solid understanding of the subject and proficiency with the platform, which can be very technical and complex.
This is where RM Boulanger comes in. With the help of our CBAM Navigator, we take care of the entire process for you. Not only do we create the complete report and deliver the required XML file, but we also handle its submission on the official platform, ensuring you peace of mind and compliance with regulatory requirements.
Declarants must prepare and submit a separate declaration for each country concerned.
4/ Submitting the report
Since the beginning of the CBAM transitional in Ocotber 2023, the reports must be submitted quarterly to the European administrative authorities via the. From July 2024 onwards, accurate values of CO2 emissions are required in the reports.
RM Boulanger is able to assist with your CBAM obligations thanks to our reliable and automated tool called the:
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in touch with you shortly, our experts are always happy to help. You can also contact us by
phone: +33 3 20 25 70 70.
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