Expert consulting to navigate the EU's landmark carbon pricing instrument — from scope determination and embedded emissions calculation to authorised declarant registration and annual certificate management.
The Carbon Border Adjustment Mechanism (CBAM) is the EU's flagship environmental policy tool that places a carbon price on imports of carbon-intensive goods. Its purpose is to prevent carbon leakage and create a level playing field between European producers operating under the EU Emissions Trading System (EU ETS) and importers from countries with less stringent carbon policies.
Under CBAM, EU importers of covered goods must account for the embedded greenhouse gas emissions of their imports. In the definitive period (from 2026), they must purchase and surrender CBAM certificates at a price linked to the EU ETS allowance auction price, expressed in /tonne of CO₂e emitted.
The regulation covers six sectors currently at highest risk of carbon leakage: cement, iron & steel, aluminium, fertilisers, hydrogen and electricity. Scope may expand to additional sectors under ongoing reviews.
The CBAM Regulation (EU) 2023/956 operates in two phases: a transitional period for reporting and data collection (2023–2025), and a definitive period from 1 January 2026 in which financial obligations apply. Free allocation under the EU ETS is being phased out in parallel, with full CBAM coverage from 2034.
Importers who import more than 50 tonnes (aggregate net mass, per year) of CBAM goods must hold the status of Authorised CBAM Declarant — a registration process with their national competent authority that must now be completed.
CBAM applies to imports of goods in the following sectors, identified by their Combined Nomenclature (CN) codes. The regulation covers both the primary goods and selected precursors and downstream products.
Clinker, hydraulic cement and associated CN codes. Monitoring focuses on calcination emissions and direct process CO₂.
Pig iron, DRI, flat and long steel products, and many downstream items. The broadest sector by product scope, covering 50+ CN codes.
Unwrought aluminium (primary and secondary), aluminium oxide, and selected downstream products. PFC emissions from primary smelting are covered.
Ammonia, nitric acid, urea, mixed fertilisers. N₂O emissions from nitric acid production require the measurement-based methodology.
All production routes: steam methane reforming (grey), autothermal reforming, electrolysis (green/blue). Embedded emissions differ substantially by route.
Imported electricity. Direct and indirect emissions accounted for. Specific default emission factors by country of origin apply.
Understanding where we are in the CBAM rollout is critical for planning your compliance obligations. The transitional period has ended — the definitive regime is now in effect.
EU importers were required to submit quarterly CBAM reports with embedded emission data — but with no financial obligation. Failure to report incurred penalties. This phase served as a "learning phase" to calibrate the monitoring and reporting framework.
CompletedImporters (or their indirect customs representatives) importing more than 50 tonnes of CBAM goods per year must be registered as Authorised CBAM Declarants. They must purchase CBAM certificates at the quarterly average EU ETS auction price (from 2027: weekly average) and surrender them annually for embedded emissions declared.
Active NowCBAM gradually covers an increasing share of embedded emissions in parallel with the phase-out of free EU ETS allowances for covered sectors. The exact percentages are defined by the European Commission on a year-by-year basis.
Phase-In100% of embedded emissions in all CBAM goods will be subject to certificate surrender. Free allocation under the EU ETS for these sectors will be fully eliminated. The CBAM will be at full operational maturity.
Full CoverageWe provide end-to-end CBAM compliance support — from first-contact assessment through to annual declaration management. Our consultants are experienced in GHG reporting, emissions monitoring and EU environmental regulation.
The first step is establishing whether your imports are subject to CBAM and to what extent. We review your product portfolio, tariff classifications and import volumes against the CBAM Annex I goods list.
Importing CBAM goods above the threshold without Authorised Declarant status is not permitted from 1 January 2026. We guide you through the complete application process with your national competent authority.
Accurate calculation of embedded direct and indirect emissions is the technical core of CBAM compliance. We design monitoring frameworks aligned with the CBAM Implementing Regulation (EU) 2023/1773.
EU importers depend on non-EU producers (operators) for emissions data. We help structure the data request process, interpret received data, and validate supplier information for CBAM compliance.
Annual CBAM declarations must be filed via the CBAM Trader Portal by 31 May each year for the preceding calendar year. We prepare, review and support the submission of all required documentation.
Importers may deduct from their CBAM obligation any carbon price already paid by the non-EU producer in the country of production. We identify and document these deductions and advise on certificate purchasing strategy.
CBAM creates obligations for different parties in the import chain, each with distinct responsibilities.
Any EU legal entity importing CBAM goods above 50 tonnes per year must apply for authorised declarant status. As a declarant, you bear the primary compliance burden.
Non-EU installations producing CBAM goods are not directly liable for CBAM, but must cooperate with EU importers to provide the emissions data required for compliance. Proactive engagement protects their export relationships.
We follow a proven four-phase methodology that takes you from initial assessment through to sustainable compliance.
Scope review: identify CBAM goods by CN code, map goods to aggregated categories, assess import volumes against thresholds, and flag any exemptions.
Build a monitoring and data collection framework: emissions methodology, supplier data request templates, and internal record-keeping processes.
Complete the Authorised CBAM Declarant application, obtain CBAM Registry account, and prepare CBAM certificate purchasing strategy.
Ongoing annual declaration management, certificate surrender, supplier re-verification, and regulatory change monitoring as CBAM matures.
The definitive CBAM regime is in effect. Importing CBAM goods without an authorised declarant account number is a compliance breach. Contact us for a rapid initial assessment and a clear roadmap to compliance.
Contact Us at info@mbo.gr