The Carbon Border Adjustment Mechanism (CBAM or CBAM in English) came into force on January 1, 2026.
The principle is simple: gradually introduce a pricing system for imports into the European Union of products with high carbon content, namely at the moment steel, aluminum, cement, nitrogen fertilizers, electricity and hydrogen.
The aim is to align the cost of carbon of these products with that of European industrialists and thus protect their competitiveness while encouraging them to decarbonize their industrial processes.
Introduced on October 1, 2023 in the European regulation, the CBAM was until then in a transitional phase. It has been fully in place since January 1 and its application has been simplified in October 2025.
How does this mechanism work? What is it for? Is your company affected? What are the simplifications voted in 2025? How to fill in your CBAM report? We go through all these questions in this article.
1. What is the Carbon Border Adjustment Mechanism (CBAM)?
The CBAM is an instrument that the European Union equips itself with to implement its Green Pact and fight against global warming.
This is an environmental measure. That is why in France, the competent authority on this issue is the Directorate General for Energy and Climate (DGEC) of the Ministry of Energy Transition.
Concretely, with the implementation of this mechanism, importers of goods (or their indirect customs representatives) must declare the direct and indirect greenhouse gas (GHG) emissions integrated into their imports, and pay a tax on these imports when crossing the EU border.
2. What are the objectives pursued by the CBAM?
The main objective remains the same as that pursued by the European Green Deal: to fight against global warming and achieve carbon neutrality by 2050.
One cannot understand the CBAM and its objective unless one relates it to the European emissions trading system (the ETS, or European Trading System in English).
In 2005, the European Union set up a European carbon market with a first taxation on CO2 emissions for producers of heavy and very carbon-intensive industries. The aim is to encourage them to decarbonize their industrial processes by making decarbonized, or less decarbonized, processes more competitive.
However, in order to cushion the extra cost for European companies, the EU decides to grant many free quotas to industrialists. This has made it possible to limit the price of the tonne of CO2.
But conditions have gradually become stricter and the famous free pollution rights will gradually disappear, their quantity decreasing year by year until their total suppression in 2034.
The cost of the tonne of CO2 should therefore gradually increase for European industrialists, who find themselves in competition with foreign competitors not subject to this mechanism.
This would potentially increase imports of products whose carbon footprint is much higher than in the EU. In other words, to weaken European companies while increasing greenhouse gas emissions elsewhere. This is what is called the phenomenon of "carbon leakage", a result contrary to the initial objectives of the European mechanism.
It is to fight against this that the carbon border adjustment mechanism was imagined: to tax imports in order to equalize the price of carbon paid by European industrialists within the framework of the ETS with the imported goods.
And the CBAM will increase in scope as free quotas disappear. The level of the tax on imports will be calculated according to the price of the emission quotas of the ETS.
3. Which companies are concerned by the CBAM?
There are several cumulative conditions for a company to be subject to the CBAM: one related to the type of product imported, the others related to the nature of the flow concerned and its amount.
- The company imports into the EU customs territory, the continental shelf or the EEZ, a product concerned and listed by the CBAM
Initially, in 2026, the CBAM only applies to a certain number of products or families of products:
- steel (except certain ferro-alloys)
- aluminum
- nitrogen fertilizers
- cement
- hydrogen
- electricity
However, on January 10, 2026, the French government said it had obtained from the European Commission a rapid suspension of the application of the CBAM on fertilizers, in order to preserve the competitiveness of farmers. This suspension would apply retroactively from January 1, 2026. The decision has not yet been definitively adopted.
The customs nomenclatures of the goods concerned are taken up in the Annex 1 of Regulation 2023/956. Moreover, the imported goods must not come from a country listed in Annex 3 of Regulation 2023/956. Overall, the products concerned are those with a high risk of carbon leakage.
- The flows concerned by the CBAM must have certain characteristics:
- It must be an “import” in the customs sense, i.e. the “placing of goods into free circulation” mentioned above
AND
- that the cumulative imports for a company must exceed 50 tonnes in the calendar year. Below this threshold, importers are exempt from the obligations related to the CBAM.
This provision was published by the European Union on October 8, 2025 in its CBAM simplification regulation. According to European authorities, this measure will make it possible to exempt 90% of importers from the CBAM rules while still covering 99% of CO2 emissions related to imports of products concerned by the CBAM.
Finally, you are not concerned if you import goods from Iceland, Norway, Liechtenstein or Switzerland.
4. What obligations are imposed on companies affected by the CBAM?
In accordance with Regulation (EU) 2023/956, which introduces the CBAM, it is Implementing Regulation (EU) 2023/1773 that establishes the rules that apply to companies affected by the CBAM.
Here are the obligations for importers subject to the CBAM:
- Obtaining the status of “authorized CBAM declarant” before importing goods subject to the scheme.
The status is granted by the Directorate-General for Energy and Climate.
To obtain it, you must:
- have a douane.gouv.fr account
- check that your account is certified
- have the authorization to connect to the MACF 2.0 registry
- submit your application on the national access portal to the European MACF registry: https://www.douane.gouv.fr/service-en-ligne/portail-dacces-national-au-registre-europeen-macfcbam-periode-definitive
Warning, without CBAM authorization, the goods under customs are not released.
The State has nevertheless introduced flexibility for the first months: importers who submit an application for CBAM declarant status before March 31, 2026 and whose application is under review can import until the end of the review and therefore before officially obtaining the status.
The Directorate-General for Energy and Climate has published a practical guide for importers in which you will find all the necessary information to obtain the status of “authorized CBAM declarant”.
- Submission of a report summarizing the import data for the calendar year, in September of the following year.
The report must include, in particular:
- the quantities imported
- the production process used
- the direct and indirect emissions associated with the goods
- or details on the calculation method used
The information to be declared in the annual report, the first of which must be submitted in September 2027, is the same as that requested in the quarterly declarations of the transitional phase, during which companies prepared for the implementation of the CBAM, between 2023 and December 31, 2025.
Again, you can consult the Directorate-General for Energy and Climate's practical guide for importers.
- In parallel, the acquisition of CBAM certificates and their return at the time of the report submission.
All companies subject to the CBAM will have to return the CBAM certificates by September 31, 2027 for the year 2026.
They must therefore carefully monitor their imports of goods throughout the year 2026 and then take stock at the beginning of 2027.
The platform for purchasing certificates will open in February 2027.
5. What other resources can help you?
To help you prepare for the implementation of the CBAM, the European Commission and the government have developed several documents that may be useful to you. Among them:
- How to complete your CBAM report?
- File - Carbon Border Adjustment Mechanism (MACF)
- Note to operators on completing the customs declaration from January 1, 2026
- The webinar of the Directorate-General for Energy and Climate of December 2025
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