Through CBAM advisory services and the compliance activities required to fulfil CBAM obligations, we support affected importers and customs representatives.
CBAM (Carbon Border Adjustment Mechanism) Advisory and Management of CBAM Compliance Obligations
In 2023, the European Union adopted legislation establishing a mechanism to address carbon intensity (CBAM, carbon border adjustment rules). EU standards, as well as the related national regulations, introduced new obligations for importers and customs representatives that require thorough and complex preparation.
Carbon border adjustment obligation – who is affected?
Companies engaged in the activities below are impacted by the CBAM / carbon border adjustment–related obligations that include CBAM registration and reporting (declarations) and, later on, the obligation to pay the carbon border adjustment charge. CBAM liable parties are companies importing the affected products from third countries, as well as their customs representatives.
Currently, the following product categories fall within the scope of CBAM:
- cement,
- electricity,
- fertilisers,
- iron, steel and aluminum products,
- chemicals.
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What does the CBAM obligation involve?
During the transitional period from 1 October 2023 to 31 December 2025, importers and indirect customs representatives are subject to CBAM registration, record-keeping and quarterly reporting obligations. From 2026, the reporting obligation will also be complemented by a CBAM payment obligation.
Challenges of CBAM compliance
The CBAM rules introduced in 2023 define ongoing obligations for businesses. These carbon border adjustment obligations are expected to gradually become more complex.
Affected businesses can meet their current and future CBAM obligations if they establish, as soon as possible, internal systems suitable for managing, recording and transmitting to the EU the data required to fulfill CBAM reporting.
Given that this is a regulatory framework in a constantly changing legal environment, anyone who wants to comply with the obligations must continuously monitor changes to the CBAM rules.
To manage CBAM obligations professionally, beyond customs law expertise, one must also be familiar with European and national environmental regulations, especially those related to carbon emissions.
Since environmental rules play a significant role alongside customs law requirements, CBAM provisions appear as complex obligations for which expert support is justified.
CBAM specialists of RSM’s Customs Business Line support the end-to-end fulfillment of carbon border adjustment obligations
- Advisory support in interpreting CBAM rules and fulfilling CBAM obligations
- Review of the company’s CBAM exposure; advisory support in determining the data required for reporting; involvement in data reporting
- Support with the company’s CBAM registration
- Establishing CBAM record-keeping; preparing the CBAM-affected company for obligations after the CBAM transitional period (2024–2026)
