Since 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM) has been in its definitive phase. For businesses importing certain goods from third countries, CBAM affects not only the reporting of embedded emissions and the purchase of CBAM certificates, but also the customs declaration itself.
Transfluvia supports importers with the customs aspects of CBAM and helps them align their import flows with CBAM obligations.
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CBAM applies to goods covered by the commodity codes listed in the CBAM legislation. These are mainly products from the following sectors:
Certain further processed products may also fall within the scope of CBAM. Whether a product is subject to CBAM is primarily determined by its CN code. Correct tariff classification is therefore essential.
Unsure about a product’s classification? Contact us for advice on tariff classification and binding tariff information (BTI).
For iron and steel, aluminium, cement and fertilisers, an annual de minimis threshold of 50 tonnes of net mass per importer applies from 2026.
If an importer remains within the applicable threshold, the de minimis exemption may apply.
If the threshold is exceeded during the calendar year, it is important to assess the consequences for both completed and planned imports in good time.
Anyone importing CBAM goods without being able to benefit from an applicable exemption must, in principle, hold the status of authorised CBAM declarant.
The application is submitted through the CBAM Registry to the competent authority of the Member State in which the applicant is established.
Transfluvia carries out customs formalities exclusively under direct representation. This means that we act in the name and on behalf of our client.
Under direct representation, the importer remains responsible for its own CBAM obligations. Transfluvia therefore does not take over the importer’s role as authorised CBAM declarant.
From 2026, CBAM-related data are included directly in the import declaration. Depending on the specific circumstances, different TARIC document codes or references may be required.
This code is used when the CBAM account number of an authorised CBAM declarant must be included in the declaration.
This code is used when the importer claims the applicable de minimis exemption.
The correct code or reference must always be determined based on the specific import, the importer and its CBAM status.
An importer initially relying on the de minimis exemption must monitor its cumulative imports throughout the calendar year.
Where the threshold can reasonably be expected to be exceeded, it is advisable to arrange the necessary CBAM status and customs handling before further imports take place.
Where goods cannot yet be released for free circulation, another customs procedure, such as storage in a customs warehouse, may be considered in certain cases.
For CBAM goods imported in 2026, the first annual CBAM declaration must be submitted by 30 September 2027.
The financial CBAM obligations are separate from the customs declaration, but the two systems are closely connected. Accurate import data are therefore essential for subsequent CBAM administration.
Under direct representation, the importer remains responsible for authorisation as a CBAM declarant, emissions reporting and CBAM certificates. Transfluvia can, of course, provide support and advice throughout these processes.
No. The threshold is assessed cumulatively per importer and per calendar year.
No. For the sectors covered by the mass threshold, the relevant masses are added together.
No. The 50-tonne mass threshold does not apply to electricity or hydrogen.
No. Transfluvia acts exclusively as a direct customs representative. Under this form of representation, the importer remains responsible for its own CBAM obligations.
This depends on your specific circumstances, your import volume and, where applicable, the status and date of an application already submitted. In that case, contact us before the goods are presented for release for free circulation.
Send us your commercial invoice, packing list, CN/TARIC code, net mass per commodity code, origin, EORI number and relevant CBAM data in good time. We will assess which information is required for the customs declaration.