New EU Regulation – Carbon Border Adjustment Mechanism (CBAM)

Do you import goods with a value exceeding EUR 150 from third countries? Do you import steel, aluminium, iron, cement, electricity, fertilisers, hydrogen or products made from these commodities?

If you answered yes to both questions, you have come to the right place. We can help you navigate the fast-changing CBAM legislation to ensure you avoid any penalties.

What is the CBAM and how does it work?

From 1 October 2023, the CBAM Regulation introduced an EU carbon border adjustment mechanism, stipulating obligations for companies importing goods from third countries. It is the EU’s tool to put a fair price on carbon emitted during the production of goods entering the EU. During the transitional period, from 1 October 2023 to 31 December 2025, importers are subject to new administrative and reporting obligations with respect to imports and emissions embedded in imported goods. Once the permanent system comes into effect on 1 January 2026, in addition to administrative and reporting obligations, importers will also be obliged to provide financial compensation by the purchase of CBAM certificates according to the amount of emissions embedded in goods imported from third countries. The CBAM applies to companies based in the EU and primarily their supply chains. You are obliged to report information from your suppliers on emissions and production processes. 

Do not hesitate to contact us for advice on compliance with CBAM obligations.

Which sectors does the CBAM cover?

  • Steel, iron, and selected articles made from these materials – eg tubes, profiles, sheets, drums, casks, cans, bolts, nuts, and goods classified as other articles of iron or steel included under customs tariff number 7326.
  • Aluminium and selected articles of aluminium – eg tubes, profiles, sheets, drums, casks, cans, and goods classified as other articles of aluminium included under customs tariff number 7616.
  • Cement – eg aluminous cement, certain types of Portland cement, and goods classified as other kaolinitic clays and other hydraulic cements.
  • Fertilisers – eg nitric acid, ammonia, potassium nitrates, certain mineral or chemical fertilisers.
  • Hydrogen
  • Electricity

How we can help you?

  • We will identify which of your imported goods will be subject to the CBAM. 
  • We will assist you with the preparation of a CBAM report and registration in the CBAM Transitional Registry. 
  • We will summarise your obligations during the transitional period and after the full implementation of the CBAM and the timetable for compliance and potential penalties. 
  • We will train you to ensure you understand the new legislation and are prepared for the different implementation stages of the carbon border tax. 
  • We will determine whether your suppliers are prepared for the CBAM and design a communication strategy to obtain key data from your suppliers.
  • We will provide you with reliable monitoring of legislative changes in this area, so nothing of importance escapes your attention.


Do not hesitate to contact us. We will provide you with tailored advice across departments and advice on compliance with CBAM obligations.

Dagmar Yoder

Local Partner | Legal

Lukáš Koporec

Senior Consultant | Tax