The final phase of the Carbon Border Adjustment Mechanism (CBAM) will come into effect as of January 1st, 2026. This means that importers of CBAM goods (iron, steel, aluminium, cement, fertiliser, electricity and hydrogen) within the EU, will be forced to deal with new reporting and payment obligations.

As your direct representative, Van der Helm would like to inform you in a timely manner about what will change and what you need to prepare for. This will ensure that your shipments will not come to a standstill at the border on 1 January.

Simplifications Omnibus Package

The European Commission wants to make the implementation of the CBAM regulation easier for companies. The simplifications will take effect on January 1, 2026, the same moment the entire regulation comes into force.

The simplifications ensure that you are excluded from CBAM obligations if you import less than 50 tonnes of CBAM goods during the calendar year. In this case you do not have to obtain a CBAM declarant authorisation, you do not have to submit a CBAM declaration and you do not have to purchase CO2 certificates.

What will change on 1 January 2026

From 1 January 2026, customs will accept import declarations (with CBAM goods) in two ways:

• A CBAM account number (obtained through the CBAM declarant application) must be stated on the import declaration.
• A declaration must be submitted: stating that less than 50 tonnes of CBAM goods will be imported during the calendar year.

CBAM declarant application

If you wish to import (more than 50 tonnes) CBAM goods annually, you will need a CBAM declarant authorisation. Van der Helm cannot finalize the clearance, without the CBAM declarant account number. If you have not already completed this process, we recommend that you do so promptly. It is possible that the authorisation application may not be processed by 1 January 2026, which will prevent you from importing goods.

Declaration for less than 50 tonnes per calendar year

Importers with less than 50 tonnes (CBAM-goods) per calendar year will need to submit a declaration, in order for Van der Helm to finalize the clearance. Additional information about the requirements of this declaration for less than 50 tonnes per year, will be announced later.

You are not an authorised CBAM declarant, but your imports of CBAM goods exceed 50 tonnes

You can still apply to the NEa for authorisation as a CBAM declarant. If your application is accepted, the NEa has a maximum of 120 days to process it.

Please note: in this scenario, you cannot import CBAM goods during the processing period!

You are responsible for monitoring the threshold value of 50 tonnes of CBAM goods. However, the European Commission may issue notifications to importers who are likely to import more than the threshold value.

Reporting obligation

From 1 January 2026, annual reports must be submitted on imported CBAM goods.

Purchase of certificates

Importers must purchase CBAM certificates for the CO2 emissions emitted during the production of the imported goods. The quantity of certificates must correspond to the actual emissions.

Obtaining emissions data and chain transparency

You must have reliable data on the CO2 emissions of your producers outside the EU. Sometimes default values will apply if your own data cannot be provided, but these will be less favourable (financially).

Legal and compliance risks

Errors in emission data or incomplete/incorrect reporting may result in goods being refused and/or fines being imposed.

Check whether you intend to import CBAM goods as of 1 January 2026 and prepare accordingly. If you have any further questions, please feel free to contact one of our specialists.