CBAM Regular Phase starts on 1 January 2026 – Check your authorisation and secure imports now
As of 1 January 2026, the regular phase of the Carbon Border Adjustment Mechanism (CBAM) will begin. Companies importing affected goods into the European Union will then require the status of an authorised CBAM declarant. Otherwise, an import ban may apply.
Who is affected by CBAM?
The obligation applies to all importersand indirect customs representatives importing products such as iron, steel, aluminium, fertilisers, cement, hydrogen or electricity into the customs territory of the Union. Indirect customs representatives – e.g. logistics service providers – must also be authorised, regardless of the quantity imported.
If you are unsure whether your company is affected, we will be happy to advise you in a free initial consultation.
By when must companies register as CBAM declarants?
Companies falling within the scope of CBAM Regulation (EU) 2025/2083 (amending Regulation (EU) 2023/956) are advised to submit their application for authorisation as a CBAM declarant via the CBAM Registry during 2025.
From 1 January 2026, only authorised CBAM declarants may import goods into the customs territory of the Union (cf. Article 4 CBAM Regulation).
At the same time, the CBAM Omnibus Reform I (COM (2025) 87), adopted by the European Parliament, introduces a limit of 50 tonnes per year – the so-called mass-based threshold.
Anyone exceeding this limit must
- hold an authorisation, or
- have submitted an application no later than 31 March 2026 (Article 17(7a) CBAM Regulation).
Import without authorisation will only be permitted in two cases from 2026 onwards:
- Below 50 tonnes per year (hydrogen and electricity not included) without an indirect customs representative. This exemption must be indicated in the customs declaration.
- Ongoing authorisation procedure: The application has been submitted via the CBAM Registrybefore 31 March 2026. In this case, imports may continue provisionally until the competent authority has taken a decision.
For the import of hydrogen and electricity, authorisation is required regardless of the imported quantity.
What changes will apply to the CBAM customs procedure from 2026?
From 2026, authorised companies are expected to provide additional information in customs procedures when importing.
The European Commission is currently developing the technical specifications and forms that will be required for this purpose.
As soon as further details are published, we will inform you on our website.
How can companies best prepare for CBAM?
The new CBAM regular phase raises many detailed questions – particularly regarding practical implementation and compliance with deadlines.
With our professional support and the MAYGREEN CBAM Facilitator, you can ensure that your company is well prepared.
CHECKLIST for companies affected by CBAM
We recommend reviewing the following points to ensure compliance:
- Assess whether your company falls under the CBAM Regulation,
- take into account the amendments introduced by the Omnibus Package relating to iron, steel and aluminium in emission calculations.
- Record the relevant product groups and data in a structured manner,
- carry out an economic assessment to compare the costs of using default values and actual data,
- prepare for the purchase of certificates from 2027 onwards.
- Organise internal processes to ensure that deadlines and requirements are met.
- Document your reports in a transparent and in a compliant manner.
This way, you stay in control and ensure that your CBAM obligations are fulfilled accurately and on time.
If you would like to know which steps make sense in your particular case, please feel free to arrange a free initial consultation.