What is the EU Carbon Border Adjustment Mechanism (CBAM)?
The EU Carbon Border Adjustment Mechanism (CBAM) is a climate measure and part of the EU Fit for 55 package initially applying to 6 sectors, including electricity. The aim of CBAM is to address the risk of carbon leakage by ensuring equivalent carbon pricing for imports and domestic (EU) production that is subject to carbon costs under the EU ETS.
From January 2026, importers into the EU will be required to report on the emission content of goods (including electricity) and purchase CBAM certificates for non-EU products.
A transitional period began on 1 October 2023. During this period, importers of electricity into the EU are required to submit a quarterly report of the embedded emissions in the imports. You will not have to make any monetary payments until 2026, at which point you or your customs representative will be expected to buy and surrender CBAM certificates corresponding to the quantity of embedded emissions in the goods.
More updates and the latest information can be found on the website of the European Commission here. The link to the transitional registry, guidance documents and webinar (eLearning) recordings can also be found here.
CBAM obligations for imports into the Netherlands
When you have been allocated capacity for electricity import into the Netherlands on the BritNed cable and you have nominated this, you are required to report CO2 emissions embedded in the imported electricity.
The Dutch Emissions Authority (NEa) have provided an update regarding Carbon Border Adjustment Mechanism (CBAM) obligations for electricity imports into the Netherlands.
Read the update here: CBAM Update – Dutch Emissions Authority
Support
Below is a list of companies that may support CBAM declarants with their reporting:
Deloitte
Deloitte can be your partner for the end-to-end CBAM compliance of electricity imports, from being your customs broker to being your CBAM agent.
Visit their website to learn more
Contact the Deloitte team directly:
Customs Support
Visit their website to learn more
Grant Thornton
Visit their website to learn more
FAQs & Key Updates
Please note: this page is correct at the time of publishing but details but change as more information is published
What is an authorised CBAM declarant?
An EU CBAM Authorised Declarant is an importer of CBAM goods into the EU who has been officially authorised by a national competent authority. Once granted this status, an authorised CBAM declarant can import carbon intensive goods, including electricity, produced in a third country into the EU.
The CBAM authorised declarant will be responsible for reporting their embedded emissions and purchasing CBAM certificates.
Why and when is the authorisation due?
An application to authorised CBAM declarant is required by 31.12.2025 in order for the importer to be able to import goods under the scope of the EU CBAM. In case of no authorisation, there is a risk of losing the possibility to import CBAM goods into the EU.
How to get the authorisation?
Securing this status involves an application process with the national competent authorities in the EU Member State of import. There will be no fee for the application.
Importers and indirect customs representatives will be able to lodge applications for authorisation via the Declarants Portal, while national competent authorities will be responsible for managing such authorisations.
There should be only one application per EORI number, and the authorisation shall be updated in case of any changes. Applying for an authorised CBAM declarant status in one EU Member State is enough: any CBAM declaration in an EU Member State where you import will cover any additional EU Member State that you import to.
The criteria to meet for becoming an authorised CBAM declarants, and how the application is assessed by the competent authority can be found in the Implementing Act (IA) on conditions for authorising CBAM declarants – in force since 28.03.2025 – Criteria for application (as per Article 5(5) of the CBAM Regulation) & Assessment of the application by the competent authority – Art. 4 of IA.
Treatment of Volumes (Line Losses vs. Nominated Values)
Charges should only apply to quantities actually imported after accounting for technical losses, not the overall quantity. Applying fees to electricity that was never imported is inappropriate. This distinction has been raised with the Commission, and further guidance is expected to ensure uniform application of the rules. Indeed the current CBAM legislative text is unclear at this stage.
CBAM exemption through ETS Linkage
While no formal agreement is yet in place, both the UK and EU have indicated a strong intent to link their Emissions Trading Systems (ETS) and provide a mutual (EU and UK) Carbon Border Adjustment Mechanism (CBAM) exemption for each other’s goods.
In mid -November, the EU-UK Emissions Trading System (ETS) the Council approved the linking mandate, authorizing the European Commission to begin formal negotiations with the United Kingdom.
On 17.12.25 the UK Government and EC shared that they are aiming to conclude the negotiations on linking the EU and UK ETS by the time of the next EU-UK Summit (probably mid-2026). You can find the official press release here: UK-EU – Joint Statement (HTML) – GOV.UK
Implementing Acts: Foreign Carbon Price and Deduction Methodology
A number of CBAM Implementing Acts were published by the EC on 17.12.25. The provisional publication versions of these Implementing Acts are now available on the Tax and Customs CBAM including legislation related to:
Additionally, the EU Commission has also shared a Review Report on the application of the CBAM Regulation, including recognising the UK ETS and CPS, and where the UK ETS and CPS price are higher than the EU ETS, there will be no financial liability for the electricity imported from the UK.
Whilst this guidance presents more favourable outcomes for electricity; please note that these are proposed amendments to the CBAM Regulation and would need to be agreed and adopted by the EU Commission and Parliament in the New Year.
Purchasing CBAM Certificates
Authorised CBAM declarants will buy CBAM certificates from the Member State where they are established. All purchases will take place on the common central platform which the European Commission will establish following a joint procurement procedure between the Member States and the Commission.
Since CBAM certificates will be sold only from 1 February 2027, for goods imported in 2026, the price of CBAM certificates will reflect the average price of ETS allowances during a given quarter.
Only authorised CBAM declarants will be allowed to purchase CBAM certificates. This is why it is important to be registered as CBAM declarants for the definitive phase of EU CBAM coming in on 1st January 2026.
Once you have applied to the relevant NCA (EU National Competent Authority) you will be given access to the EU CBAM registry. You can buy CBAM certificates directly through the Registry, at the weekly price set by the EU based on the ETS average. The EU publishes the average ETS price each week, which sets the price for CBAM certificates during that period. Purchases are limited to what you need and must align with reported emissions.
Submitting CBAM Certificates
30 September 2027 is the date for submission of CBAM certificates for 2026 imports.
Importers must surrender CBAM certificates equal to the verified embedded emissions from the previous year’s imports. Importers must make sure they have the required number of CBAM certificates available on their account in the national registry.
At the end of each quarter, importers must also double-check that the number of CBAM certificates on their account corresponds to at least 50% of the embedded emissions in all imported goods since the start of the calendar year.
Be aware that CBAM certificates are also non-tradable and non-transferable. This means they can’t be resold or shared across entities, unlike EU ETS allowances, and each importer is individually responsible for compliance.
Must importers apply to all member states where they import? Does this mean they will need to obtain multiple / duplicate CBAM registrations?
Importers only need to submit one application in a single Member State. That application is then shared with all other Member State authorities, who ensure compliance. Once authorised, the status applies across all Member States where you import.
The process is outlined in the implementing act, which should be reviewed for details on company obligations and procedures. The Commission has indicated that updates will follow.
For a non- EU based importer, if we have appointed an indirectly customs representative, do we also need the authorized CBAM declaration?
The importer is responsible for complying with CBAM and must obtain authorised CBAM declarant status to import. While a representative may support the process, the obligation remains with the importer. It is really important to ensure that all importers apply for Authorised CBAM Declarant status before 1st January 2026.
The CBAM Impact Study
In early 2024, a group of interconnectors, including BritNed, commissioned AFRY Management Consulting to create a report on the impact of the EU Carbon Border Adjustment Mechanism (CBAM) on electricity imports from Great Britain.
The published reports offers an impartial evaluation of the possible consequences of the EU CBAM. The full report and the executive summary of the impact study are below.
EU CBAM Impact Study Summary Report
EU CBAM Impact Study Executive Summary
The study has identified two issues with the method of application of CBAM to electricity imports from GB:
These issues unduly increase the cost of electricity imports into the EU from GB, presenting the following adverse outcomes:
Latest updates from the European Commission
The latest information can be found on the website of the European Commission (button below) along with a link to the transitional registry, guidance documents and webinar (eLearning) recordings.
Reporting during the transitional period
The European Commission has developed the CBAM transitional registry to help importers perform and report as part of their CBAM obligations. Importers must provide a CBAM report on a quarterly basis, to the European Commission via the CBAM Transitional Registry on the European Commission website.
The definitive CBAM period
The definitive period will begin on 1st January 2026. As appose to quarterly reporting, one report should be submitted annually by 31st May, with the first report to be submitted in 2027.
During the definitive period importers will need to report on the emission content of goods and purchase equivalent CBAM certificates for non-EU imports.
If importers can prove that a carbon price has been paid (e.g. through UK ETS) during the production of the imported goods, the corresponding amount can be deducted.
How do I report if my company is not based in the EU?
When the importer is established outside of the EU, an indirect customs representative will be responsible for the reporting on your behalf. More information can be found in the guidance document on CBAM for installation operators outside the EU on this webpage.
