Tim Baines

This Practice Note covers the requirements of Regulation (EU) 2023/956 of 10 May 2023 establishing the EU carbon border adjustment mechanism (the EU CBAM Regulation), as applicable for the ‘definitive’ CBAM period, from 1 January 2026 onwards. The EU CBAM establishes equivalent rules to those imposed by the EU emissions trading system (ETS) for goods with high embedded greenhouse gas emissions being imported into the EU. This Practice Note covers the scope of the EU CBAM and the obligations to submit CBAM declarations and surrender CBAM certificates as applicable from 2026 onwards. It also provides practical guidance on the calculation of embedded emissions, the administration of the CBAM via registries, and the consequences of non-compliance. This Practice Note also covers the 2025 revisions to the EU CBAM made pursuant to the Commission’s first omnibus simplification package.

This Practice Note covers the requirements of Regulation (EU) 2023/956 of 10 May 2023 establishing the EU carbon border adjustment mechanism (the EU CBAM Regulation), as applicable during the EU CBAM transition period (which ran from 1 October 2023 to 31 December 2025). The EU CBAM establishes equivalent rules to those imposed by the EU emissions trading system (ETS) for goods with high embedded greenhouse gas emissions being imported into the EU. With respect to the transition period, this Practice Note covers the scope of the EU CBAM and the obligations to submit CBAM reports and collect information. It also provides practical guidance on the administration of the CBAM via the transitional registry and the consequences of non-compliance.