The EU is updating the tariff system for CBAM integration ahead of full implementation in 2026
The European Commission has published detailed guidance on the integration of the Carbon Border Adjustment Mechanism (CBAM) into the EU TARIFF Customs System, laying the operational foundations for the mechanism to fully enter into force on January 1, 2026.
The update includes new certificates, revised import conditions, and explanatory notes to provide clarity to customs operators, as well as to prepare EU systems for the transition from temporary reporting to full-scale CBAM application.
During the transition period from October 1, 2023 to December 31, 2025, importers of CBAM products were required to submit quarterly reports detailing direct and indirect emissions, product quantities, and carbon prices paid in the exporting country.
By the end of 2025, the tariff will specify the type of measure 775, indicating that imports fall within the scope of CBAM. However, certificates are not required at this stage. Instead, footnote TM967 clarifies transitional reporting responsibilities and temporary exclusions.
Mandatory registration of CBAM products based on certificates
Starting from January 1, 2026, the system will change significantly. TARIFF measure 775 will contain mandatory conditions that determine whether CBAM products can be legally released into free circulation.
A set of certificates determines the permissibility of CBAM goods at customs. The Y128 certificate contains the authorized declarant's CBAM account number and is the basis for standard imports. Certificates Y134 and Y135 cover exceptions related to special geographical territories or military goods, while certificates Y136 confirm that electricity or hydrogen was produced on the continental shelf or in the exclusive economic zone of an EU member State. The Y137 certificate allows for an exception for a minimum weight of 50 tons, while the Y237 certificate defines goods manufactured in the EU and therefore excluded from CBAM obligations. The Y238 certificate is being introduced for operators whose applications for CBAM declarant status are still pending, and permits import pending a decision. If none of these certificates are applied, condition Y060 blocks the import of CBAM products.
Different operating rules have also been established for different CBAM product groups.
Different operating rules have also been established for different CBAM product groups. Cement, fertilizers, cast iron and steel, as well as aluminum, are subject to both declaration requirements and weight thresholds, reflecting a new annual de minimis exemption of 50 tons for each importer.