CBAM: phases of implementation of the carbon border adjustment mechanism

The CBAM - Carbon Border Adjustment Mechanism (Carbon Adjustment Mechanism at the borders)

The CBAM, introduced with EU Regulation 956/2023, is an environmental levy (applied on a transitional basis from October 1, 2023, to December 31, 2025). It will impact, starting from its definitive entry into force on January 1, 2026, certain listed goods whose production is of “high carbon intensity”, such as cement, cast iron, iron, steel, aluminum, hydrogen, electricity, fertilizers, subject to release into free circulation in the EU customs territory.

The CBAM regulation aims to address the issue of greenhouse gas emissions embedded in non-EU goods subject to importation (listed in its Annex I), taxing those produced based on production standards less stringent than those of the EU. This is to prevent the risk of carbon emissions relocation abroad by EU industries, thereby reducing global emissions and supporting the goals of the 2015 Paris Agreement. The regulation also encourages emission reduction by non-EU operators.

The regulation applies to goods listed in the aforementioned Annex I, originating from a third country. This includes the products processed from such goods following au...