CBAM advisory for CBAM compliance

CBAM advisory for CBAM compliance 

We provide CBAM advisory for the CBAM compliance of importers and customs representatives.

In 2023 the European Union adopted a regulation establishing a carbon border adjustment mechanism (CBAM; CBAM rules). The EU standards and related national legislation have introduced new obligations for importers and customs representatives, which require elaborate preparation. 

Entities subject to CBAM

Companies engaged in the following activities are subject to the CBAM registration and payment obligations. Companies importing specified products from third countries and their customs representatives are subject to the CBAM.

Products covered in the current phase of the CBAM:

• cement,
• electricity, 
• fertilisers, 
• iron, steel and aluminium, 
• chemicals.   

MORE ABOUT CBAM ADVISORY

CBAM obligations:

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. As of 2026, the data reporting obligation will be complemented by a CBAM payment obligation.

Challenges of CBAM compliance

The obligations of entities set out by the CBAM regulations introduced in 2023 are expected to become increasingly complex. 

In order to comply with their current and future CBAM obligations, the entities concerned are required to introduce appropriate internal systems for the management, recording and reporting of the data to the EU.

In a constantly changing legal environment, entities wishing to comply with the obligations must monitor changes to the CBAM rules.

Also, it is necessary to be aware of European and national rules on environmental protection, including carbon emissions, in addition to customs law. 

Given the importance of environmental rules in addition to customs rules, the CBAM requirements are complex obligations that require expert assistance to meet them properly. 

The CBAM specialists in RSM's customs service line can help you fully comply with your CBAM obligations

• CBAM advisory to help you interpret and meet CBAM obligations 
• Reviewing the company's CBAM obligations, advising on the definition of the data required for the declaration, assisting in data reporting
• Assistance with your CBAM registration
• Developing a CBAM registry, preparing the company for the obligations after the transitional period (2024-2026)