CARBON BORDER ADJUSTMENT MECHANISM
Regulation (EU) 2023/956 of the European Parliament and of the Council (CBAM Reg.) established the Carbon Border Adjustment Mechanism (CBAM).
The purpose of the CBAM is to prevent the risk of carbon leakage and encourage cleaner industrial production in countries outside the EU, to address the greenhouse gas emissions embodied in certain carbon-intensive goods (Annex I of the CBAM Regulation), upon the import of these goods into the customs territory of the European Union (EU).
The general categories of goods included in Annex I of the CBAM Regulation are those of cement, iron and steel, aluminum, fertilizers, electricity and chemicals (hydrogen), which are specified with Taric, Combined Nomenclature or Harmonized System codes.
TRANSITIONAL PERIOD OF CBAM – UNTIL 31-12-2025
In order to facilitate the smooth implementation of the Regulation, a process of gradual integration of the requirements of the Regulation into the economic reality of the EU was followed, with the provision of a transitional period until 31-12-2025. During this period, importers/declarants submitted quarterly reports on imports of goods of Annex I to the Regulation, in accordance with the Commission Implementing Regulation (EU) 2023/1773. This gradual introduction into the Regulation’s logic is in line with the gradual abolition of free allowances under the EU Emissions Trading System (ETS), to support the exemption of EU industry from greenhouse gas emissions.
CBAM CUSTOMS REQUIREMENTS - FROM 01-01-2026
From 01-01-2026, the date of full implementation of the CBAM, goods falling within the scope of the CBAM Regulation are imported into the customs territory of the EU only by an Authorized CBAM Declarant (importer/indirect customs representative), or by an importer/indirect customs representative who has submitted an Application for Licensing by 31-03-2026.
Every importer established in a Member State, or his indirect customs representative, before importing into the customs territory of the Union, goods falling under the CBAM and exceeding the single threshold based on mass (50 tonnes net mass) but also before importing electricity and hydrogen regardless of the mass limit, submits an application to the Competent National Authority to acquire the status of Authorized CBAM Declarant (relevant instructions are provided in the relevant link: v.1-Instructions-for-CBAM-licensing.pdf.
When an importer, who imports goods falling under the CBAM Regulation, is not established in a Member State, his indirect customs representative acquires the status of Authorized CBAM Declarant, regardless of whether the importer is exempted, in accordance with article 2a, from the obligations of the CBAM Reg.
The customs requirements from 01-01-2026 are summarized in the mandatory reference in the customs declaration or in the settlement invoice submitted in accordance with Article 175(5) of Delegated Regulation (EU) 2015/2446, of the unique CBAM account number, taking into account the exceptions provided for in Article 2, Article 2a and Article 17(7a) of the CBAM Regulation (Circular E2110/30-12-2025).
The following Taric codes are appropriate for use in box 44.1 of the customs declaration in the context of the application of the CBAM Regulation:
Y128: Unique CBAM Account Number
SPECIAL INDICATIONS - REFERENCES
Y422: When goods listed in Annex I of the CBAM Regulation are placed under the inward processing procedure, this TARIC reference code, which is not linked to TARIC measures, must be declared in all subsequent declarations, until customs supervision for the processed goods is definitively terminated, either by release for free circulation or by re-export.
Y400: BE, Y401: BG, Y402: DK, Y403: DE, Y404: EE, Y405: IE, Y406: GR, Y407: ES, Y408: FR, Y409: HR, Y410: IT, Y411: CY, Y412: LV, Y413: LT, Y414: MT, Continental shelf or exclusive economic zone of the Member State to which the relevant goods or processed products are to be transported (Article 8 of Regulation 2025/2210)
EXCEPTIONS – DEROGATIONS – GOODS THAT DO NOT FALL UNDER THE CBAM REGULATION
Y238: Unique reference number of the application for the acquisition of the status of Licensed CBAM Declarant (derogation of article 17§7a)
Y137: De minimis exception (article 2a), Y134: Exception of article 2§4, Y135: Exception of article 2§3, Y136: Exception of article 2§3a
Y237: The CBAM Regulation does not cover the goods of Annex I of the CBAM Regulation, which have lost their customs status as Union goods but are goods of EU origin (article 2§1)
REQUIREMENT TO SUBMIT A CBAM DECLARATION
By 30 September of each year, and for the first time in 2027 for the year 2026, the Licensed CBAM Declarant submits a CBAM Declaration to the CBAM Registry for the emissions incorporated in the imports that concern him, of the previous calendar year, and delivers the corresponding number of certificates each year.
The Licensed CBAM Declarants from 01/02/2027 (Article 20(1) of the CBAM Reg.) purchase CBAM certificates from the national Competent Authorities of their country of establishment, the price of which is calculated based on the auction price of the EU ETS allowances, expressed in €/tonne of CO2 emitted, as a quarterly average for the embodied emissions declared for the year 2026 and as a weekly average from 2027 onwards. These certificates are purchased through a common central platform created and managed by the European Commission.
COMPETENT NATIONAL AUTHORITY OF THE CBAM (LICENSING, SUBMISSION OF DECLARATIONS)
The Directorate-General of the Financial and Economic Crime Unit has been designated as the competent National Authority for the fulfillment of the responsibilities and duties arising from the CBAM Regulation in our country, with the following contact details:
Address: 207 Pireos & 92 Alkifronos, P.C. 118 53 Athens
Email address: cbam@aade.gr
Telephone numbers: 2103401016 and 2103424657.
From 16-03-2026, the fulfillment of the responsibilities and duties, as the Competent National Authority, arising from the CBAM Regulation, is transferred to the 3rd Department of the Customs Procedures Directorate of the Directorate General of Customs & Excise Tax of the IAPR, with the following contact details:
Address: 180 Pireos, P.C. 177 78 Tavros
Email address: cbam@aade.gr
Telephone numbers: 2131410620
The website of the Competent National Authority for the implementation of the CBAM Regulation in the EU internal market, for the provision of information regarding the CBAM and the requirements for submitting an application for obtaining the status of Licensed CBAM Declarant can be found at the link: https://minfin.gov.gr/forologiki-politiki/michanismos-synoriakis-prosarmogis-anthraka/
The European Commission's website for the CBAM is located at the link: Carbon Border Adjustment Mechanism - Taxation and Customs Union