CBAM Carbon Border Adjustment for Customs

• We work on the basis of CBAM Regulation (EU) 2023/956, in force since 17 May 2023.
• Transitional period 1 October 2023 to 31 December 2025: pure reporting obligation on imported emissions, no certificate cost - we filed the quarterly reports.
• Definitive period from 1 January 2026: we register you as an authorised CBAM declarant, calculate the certificate volume and submit the annual CBAM declaration.
• We coordinate with the competent authority for you: the German Emissions Trading Authority (DEHSt) at the Federal Environment Agency.
• Implementing Regulation (EU) 2023/1773 governed report format and data quality for the transitional period; since 2026 we implement the requirements of the amended CBAM Regulation for the definitive period in your reporting.

We screen which of your non-EU imports fall under CBAM. The obligation is tied to the CN code — Annex I of the CBAM Regulation defines the product groups in scope. We classify every line cleanly so that incorrect codes never trigger CBAM errors or sanctions.

• Iron and steel (e.g. semi-finished products, sheets, tubes, screws, bolts, rails, structures).
• Aluminium (semi-finished products, profiles, wire, foils).
• Cement and cement-based products.
• Fertilisers (nitrogen and multi-nutrient fertilisers).
• Hydrogen.
• Electricity (from non-EU countries).
• Certain upstream and downstream products (precursor goods and downstream goods).

We verify the 50-tonne de-minimis threshold under CBAM Omnibus Regulation (EU) 2025/2083 (in force since 20 October 2025). From 1 January 2026 a uniform, mass-based de-minimis of 50 tonnes total net mass per importer per calendar year applies to all CBAM goods except electricity and hydrogen — i.e. iron/steel, aluminium, cement and fertilisers. If you fall below it, we document the exemption from declarant duties and certificate surrender cleanly. We cumulate all your CBAM shipments across the calendar year and alert you in good time before the threshold is reached.

• We filed the quarterly CBAM reports until the end of 2025 through the EU Commission's CBAM Transitional Registry.
• We met the reporting deadline: one month after the end of each quarter (last report Q4 2025 by 31 January 2026).
• We bundled imported quantities, CN codes, country of origin and embedded direct and indirect emissions into audit-ready reports.
• We applied the 80/20 rule that applied from Q3/2024 (1 July 2024): at most 20% of the embedded emissions of complex goods could be based on estimates such as default values, the remainder on primary data from your suppliers - we collected the data in a structured way.
• We made sure no late or faulty reports triggered sanctions, even though no certificate cost arose during the transitional period.

• We register you with DEHSt as an authorised CBAM declarant in good time before your first CBAM-relevant import in 2026.
• We file your annual CBAM declaration for the previous year - deadline 30 September of the following year (CBAM declaration 2026 by 30 September 2027).
• We calculate your certificate volume in the amount of embedded emissions, deduct documented carbon pricing in the country of origin and procure the certificates.
• We manage certificate purchases from the start of sales on 1 February 2027 and the first certificate surrender by 30 September 2027 for your 2026 imports.
• We coordinate verification of the emissions data with accredited verifiers as soon as you want to use actual values instead of default values.

We decide with you, per product group, whether to calculate with European Commission default values or use actual supplier emissions data. Default values are conservative and usually higher than real figures — fast to apply, but more expensive in certificate cost. Actual values require documented measurement and calculation procedures at the manufacturer in the non-EU country plus verification by accredited verifiers. We engage your suppliers early, clarify data quality and run both scenarios against each other so you choose the economically sound option.

• We classify your import declaration cleanly - the CN code triggers the CBAM obligation, no errors are allowed here.
• From 2026 we record your CBAM declarant status in the ATLAS declaration so customs releases the goods into free circulation.
• We mirror import volumes from ATLAS straight into your CBAM declaration - customs and CBAM data stay consistent.
• We extend your supplier master data to include emissions data and production sites, not just customs value and origin.

We keep you sanction-free. In the transitional period (2023–2025), fines for reporting breaches ranged from EUR 10 to 50 per tonne of CO₂ equivalent. In the definitive period from 1 January 2026, the penalty is at least EUR 100 per non-surrendered tonne of CO₂ equivalent (Art. 26 Regulation 2023/956 in conjunction with Art. 16(3) Directive 2003/87/EC, inflation-indexed) — plus post-clearance demands, correction obligations and reputational damage. We act with particular rigour on repeated violations because withdrawal of CBAM declarant status will stop your future imports at the border. That is why we run your annual declaration and the quarterly check of your certificate holdings on a fixed schedule with internal four-eyes review.

• We identify your CBAM-relevant goods by CN code and check volume flows against the 50-tonne threshold.
• We register you as a CBAM declarant and handle every follow-up question with DEHSt.
• We build consistent master data between customs declaration (ATLAS), supplier master data and CBAM reporting.
• We train your procurement and planning teams on CBAM requirements towards suppliers (emissions data, verification).
• We hand over the data in a structured format to your sustainability and controlling teams.