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CBAM: new obligations for importers

The Carbon Border Adjustment Mechanism (CBAM) is the European Union’s key tool to combat climate change. It aims to eliminate the risk of ‘carbon leakage’ where production is moved to countries with less stringent emission standards. New obligations for importers are now on the horizon, starting from 2026, and companies need to prepare now.

The CBAM registry, which works as a central digital platform, enables importers and installation operators to meet their emissions reporting obligations. In the current transitional period, which lasts until the end of this year, importers are obliged to report the emissions contained in their products to the relevant authorities on a quarterly basis, but for the time being without having to pay a fiscal charge for these emissions.

From 2026, when the CBAM enters its final phase, the requirements for importers will become stricter. Imports of goods subject to the CBAM will only be possible by authorised CBAM declarants, which are entities authorised by national authorities. The registration of the status of authorised CBAM declarants is carried out by the Czech Customs Administration. These entities will have to annually declare the quantity of goods imported and the corresponding emissions, as well as surrender the required number of CBAM certificates to be purchased during the year. The price of these certificates will correspond to the average weekly price of emission allowances in the EU ETS.

The Customs Administration has recently issued several practical guidelines on how to obtain the authorised CBAM declarant status. In this regard, we recommend that all entities affected by CBAM register and obtain the status well in advance.