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CBAM: entering the definitive EU carbon tariff period

We are here for you to avoid unnecessary risks and comply with the new rules associated with the carbon border tax, including timely submission of the annual CBAM declaration

EU regulation on emission reduction, aimed at ensuring greater competitiveness for companies, is from 1. ledna 2026 in the definitive period. We will help you prepare for the new rules and thus avoid the risk of sanctions.

What is CBAM and how will it work in practice?

In the period from October 1, 2023 to December 31, 2025 the CBAM transition period took place, during which importers were subject to new administrative and reporting obligations, particularly the obligation of čtvrtletně podávat CBAM reports on imports made and emissions contained in imported goods, but without financial obligations. In addition, from 2027 onwards, it will be necessary to hold a minimum share of the necessary CBAM certificates  on an ongoing basis, which mayaffect the cash flow and liquidity of companies.

From January 1, 2026 CBAM is applied within the definitive (permanent) mechanism. K administrativním a oznamovacím povinnostem se nově přidává také finanční vyrovnání emisí formou nákupu certifikátů CBAM, a to podle množství emisí obsažených v dovezeném zboží ze třetích zemí. CBAM does not apply if the importer does not exceed 50 tons of selected CBAM goods annually (does not apply to electricity and hydrogen). After exceeding this limit, it is necessary to have the status of an approved CBAM declarant and fulfill all obligations for the given calendar year.

CBAM nedopadá jen na společnosti se sídlem v EU, significantly impacts i their supply chains. Suppliers are a key source of information about production processes and emissions, which importers are required to collect and report within CBAM.

How we can help you:

We will assess whether and how CBAM applies to you – we will identify affected products, trade flows, and the role of your contractual partners in the supply chain, including assessment of the de minimis exception.

We will help you fulfill the obligations of a CBAM declarant in the definitive period, especially with setting up processes for data collection on emissions and working with the CBAM registry. If you do not yet have the status of an approved declarant, we will provide assistance.

 We will prepare you for the annual CBAM declaration, including the methodology for calculating emissions, working with actual or standard values, and linking to CBAM certificates. We can calculate the approximate financial burden related to the purchase of certificates.

We will ensure contractual treatment of CBAM obligations – we will prepare and revise contractual arrangements with suppliers of goods covered by the CBAM and other partners so that they clearly enshrine obligations regarding the provision of emission data, cooperation on reporting and responsibility for the accuracy of data. At the same time, we will help you set up the principles of cost-sharing in connection with the CBAM and take into account the carbon price in the third country in trade and pricing arrangements.

We will train your teams to understand CBAM obligations in practice and be able to fulfill them long-term across relevant departments (compliance, purchasing, finance, logistics).

We will verify the readiness of your suppliers to provide necessary data on production processes and emissions and propose an effective communication strategy for obtaining and verifying them.

We monitor legislative developments of CBAM and related implementing regulations and help you evaluate how changes impact your specific obligations.

We provide tailor-made targeted advice, tailored to your structure, import volumes and internal process settings.

We will compare the financial costs based on the actual and/or standard emission values of imported goods for individual suppliers, prepare an overview and modelling of the quarterly costs of purchasing CBAM certificates from 2027 onwards, and analyse the development of the overall financial burden associated with CBAM in the period 2026–2034, including scenarios based on the development of allowance prices and changes in the structure of suppliers.

We will design a methodology for calculating CBAM-related costs for your specific products and supply chains, ensure the implementation of relevant calculations and data flows into your internal system (ERP/reporting) and set up automated outputs for cost planning, reporting and preparation of the annual CBAM statement.

Which sectors will CBAM cover?

  • Steel, iron, and selected articles of these materials – for example, tubes, profiles, sheets, drums, barrels, cans, bolts, nuts, or goods classified as other articles of iron or steel included under customs tariff number 7326.
  • Aluminium and selected articles of aluminium – for example, tubes, profiles, sheets, drums, barrels, cans, as well as goods classified as other articles of aluminium included under customs tariff number 7616.
  • Cement – for example, aluminous cement, certain types of Portland cement or goods classified as other kaolinitic clays and other hydraulic cements.
  • Fertilisers – for example, nitric acid, ammonia, potassium nitrates, certain mineral or chemical fertilisers.
  • Hydrogen
  • Electricity