Is your company ready for CBAM?

Carbon Border Adjustment Mechanism (CBAM) is a key tool in EU's fight against climate change and in the goal of achieving net zero emissions. CBAM is intended to ensure that companies outside the EU are subject to the same requirements as European companies. This means that importers of certain goods into the EU must purchase CBAM certificates to ensure that the imported goods meet the same strict environmental standards as goods produced within the EU. If the goods have higher CO2 emissions, the importers must pay the difference.

At Bureau Veritas, we are your partner in ensuring compliance with the complex CBAM regulations. We offer a wide range of services to help you navigate the requirements—but first, let’s take an overview of what CBAM is.

Ambitious Goals and Implementation

CBAM, which entered into force on 1 October 2023, is designed to ensure that companies within and outside the EU compete on equal terms.

This is achieved by imposing, from 2027 after the transitional phase, a price on imports of goods produced outside the EU that have high CO₂ emissions.

During the transitional period, the regulation requires companies to report the embedded CO₂ emissions of imported goods within the categories of iron, steel, aluminium, cement, fertilisers, electricity, and hydrogen. [i]

Reporting is carried out at customs code level and must be submitted quarterly to a CBAM registry, which in Denmark is administered by the Danish Energy Agency and is linked to a common EU‑wide registry.

Companies are subject to reporting obligations if they import goods from a country outside the EU customs territory within the specified product categories, in a total quantity of 50 tonnes or more per year.

From 1 January 2026, importers must annually declare the quantities of imported goods as well as their embedded CO₂ emissions from the previous year.

From 1 January 2026, the EU methodology using default values will be permitted. However, companies should assess whether it is more advantageous to use actual direct CO₂ emission values instead of default values.

If specific direct CO₂ emission values are used, these must be verified by an approved third‑party verifier.

If direct and indirect emissions are used, the report must include data on production methods and emission parameters to ensure full transparency of environmental impacts.

Companies must either be approved CBAM declarants themselves or make use of an external authorised CBAM declarant.

The reported CO₂ emissions must be converted into CBAM certificates, which are priced in line with the EU CO₂ quotas. This settlement will take effect from 2027.

Penalties for missing or incorrect reporting are expected to range from €10 to €50 per tonne of CO₂.

[i] https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en

The role of the importer in cbam

"Importers have the primary responsibility for enforcing CBAM," explains Mark Fraser, Sustainability Business Development Manager at Bureau Veritas. "They play a key role in reporting, data collection, verification, and compliance." Importers must submit detailed information, including the declarant's identity, address, role, and information about importers and representatives. CBAM also requires documentation of all imported commodities – including customs tariff numbers, country of origin, and emissions (direct and indirect). The report must include data on production methods and emission parameters to ensure full transparency of the environmental impact. This type of reporting is similar to reporting required under the EU ETS (EU CO2 Emissions Trading System) – a system that Bureau Veritas is approved to verify and has gained much experience with, since the start of the scheme in 2005.

prepare the company for cbam: necessary steps

Companies must now identify affected goods, calculate emissions reductions, and work to reduce their CO₂ footprint. CBAM provides new insights and opportunities to reduce Scope 3 emissions, which companies should take advantage of.

Bureau Veritas is ready to support companies with the cbam implementation

Bureau Veritas helps companies prepare for the implementation of CBAM through advisory services and support with:

  • determining their CO₂ footprint
  • engaging in dialogue with non‑EU suppliers
  • assessing customs codes
  • reporting data
  • navigating the new regulation and ensuring compliance when CBAM is fully implemented at the end of 2026


Annette Struwe, Customer Relations Manager
Telefon: +45 2530 7644 | Mail: annette.struwe@bureauveritas.com

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