Carbon Border Adjustment Mechanism (CBAM) brings significant changes for importers

• certain iron and steel goods
  • Derivative goods such as screws, bolts and washers.
• iron ore
• certain fertilisers
• certain aluminium goods
• certain cement goods
• certain chemicals
• electricity.

CBAM regulation does not cover the following:

• consignments of low value, i.e. no more than 150 euros (Duty Relief Regulation, Article 23)
• CBAM goods brought in personal luggage with a combined value of no more than 150 euros. 
• goods used for military purposes
• goods originating in Iceland, Liechtenstein, Norway or Switzerland
• goods originating in the territories of Büsingen, Helgoland, Livigno, Ceuta or Melilla.

---

Please note that this list cannot be used for tariff classification of goods. Always check the correct commodity code in the Fintaric service.

Cement

You will find these commodity codes in the Fintaric service, under section V of the nomenclature, Minerals.

• 2507 00 80 Other kaolinic clays
• 2523 10 00 Cement clinkers
• 2523 21 00 Portland cement: White cement
• 2523 29 00 Portland cement: Other
• 2523 30 00 Aluminous cement
• 2523 90 00 Other hydraulic cements

Electricity

You will find this commodity code in the Fintaric service, under section V of the nomenclature, Minerals.

• 2716 00 00 Electrical energy

Chemicals

You will find this commodity code in the Fintaric service, under section VI of the nomenclature, Products of the chemical or allied industries. 

• 2804 10 00 00: hydrogen as pure substance

Fertilisers

You will find these commodity codes in the Fintaric service, under section VI of the nomenclature, Products of the chemical or allied industries.

• 2808 00 00: Nitric acid; sulphonitric acids as pure substance
• 2814 Ammonia, anhydrous or in aqueous solution
  • 2814 10 00 00    - Anhydrous ammonia (gaseous ammonia NH3)
  • 2814 20 00 00    - Ammonia in aqueous solution (solution NH4OH)
  • Both above as pure substance
• 2834 21 00 Potassium nitrate as pure substance
• 3102 Mineral or chemical fertilisers, nitrogenous. This commodity code covers, among others
  • Urea, whether or not in aqueous solution
  • Ammonium sulphate; double salts and mixtures of ammonium sulphate and ammonium nitrate
  • Ammonium nitrate, solid or in aqueous solution (also for other use than as fertiliser), mixtures with calcium carbonate or other inorganic non-fertilising substances
  • Sodium nitrate
  • Mixtures of urea and ammonium nitrate in aqueous or ammoniacal solution
• 3105 (Fertilisers or mixtures of fertilisers) Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus and potassium; other fertilisers; goods of this chapter in tablets or similar forms or in packages of a gross weight not exceeding 10 kg:
  • (excluding 3105 60 00 Mineral or chemical fertilisers containing the two fertilising elements phosphorus and potassium)

Iron and steel

You will find this commodity code in the Fintaric service, under section V of the nomenclature, Minerals.

• 2601 12 00 Agglomerated iron ores and concentrates, other than roasted iron pyrites

You will find these commodity codes in the Fintaric service, under section XV of the nomenclature, Base metals and articles of base metal.

• 72 Iron and steel:
  • Primary materials; products in granular or powder form
    • (excluding the following ferro-alloys: 7202 2 ferro-silicon, 7202 3 ferro-silico-manganese, 7202 50 00 ferro-silico-chromium, 7202 70 00 ferro-molybdenum, 7202 80 00 ferro-tungsten and ferro-silico-tungsten, 7202 91 00 ferro-titanium and ferro-silico-titanium, 7202 92 00 ferro-vanadium, 7202 93 00 ferroniobium, 7202 99 10 ferro-phosphorus, 7202 99 30 ferro-silico-magnesium, 7202 99 80 other, 7204)
  • Iron and non-alloy steel
  • Stainless steel 
  • Other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel
• 73 Articles of iron or steel:
  • 7301 Sheet piling of iron or steel; angles, shapes and sections of iron or steel
  • 7302 Railway or tramway track construction material of iron or steel
  • 73 03 –73 06 Tubes and pipes of iron or steel
  • 7307 Tube or pipe fittings
  • 7308 Structures and parts of structures, of iron or steel 
  • 7309 Reservoirs, tanks, vats and similar containers, of a capacity exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
  • 7310 Tanks, casks, drums, cans, boxes and similar containers, of a capacity not exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
  • 7311 Containers for compressed or liquefied gas 
  • 7318 Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles 
  • 7326 Other articles of iron or steel

Aluminium

You will find these commodity codes in the Fintaric service, under section XV of the nomenclature, Base metals and articles of base metal.

• 7601 Unwrought aluminium 
• 7603 Aluminium powders and flakes 
• 7604 Aluminium bars, rods and profiles 
• 7605 Aluminium wire
• 7606 Aluminium plates, sheets and strip, of a thickness exceeding 0,2 mm 
• 7607 Aluminium foil of a thickness not exceeding 0,2 mm 
• 7608 Aluminium tubes and pipes
• 7609 00 00 Tube or pipe fittings, for example, couplings, elbows, sleeves
• 7610 Aluminium structures and parts of structures; aluminium plates, rods, profiles, tubes and the like, prepared for use in structures
• 7611 00 00 Reservoirs, tanks, vats and similar containers, of a capacity exceeding 300 litres
• 7612 Casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), of a capacity not exceeding 300 litres
• 7613 00 00 Aluminium containers for compressed or liquefied gas, for example compressed air bottles
• 7614 Stranded wire, cables, plaited bands and the like, of aluminium, not electrically insulated:
• 7616 Other articles of aluminium: Nails, tacks, staples, screws, bolts, nuts, rivets, cotters, cotter pins, washers and similar articles, cloth, grill, netting and fencing, other articles of aluminium

---

• Find out whether your import goods are CBAM goods covered by the CBAM regulation.
• Make sure that you receive all the information you need for the transitional period reports from the manufacturer or seller of the goods.
• You will need an EORI number for importing and reporting CBAM goods.
• Create a process for reporting.
• Gather the import data to be reported from 1 October 2023, and prepare to report to EU’s Commission.
• To avoid sanctions, please report the data on time, then you can apply for a CBAM declarant certificate
• Prepare yourself for the time after the transitional period: acquire the CBAM declarant certificate already during 2025.
• Stay updated on the situation:
  • Customs pages on CBAM
  • Commission's information page Carbon Border Adjustment Mechanism (europa.eu)

---

Who is required to report?

Importers or their representatives submit quarterly reports on the import of CBAM goods to the Commission.

Please note:

• If you have declared the CBAM goods yourself, you must also submit the report yourself.
• If you have used a representative, and the representative has declared the goods acting as a direct representative, you must submit the report yourself.
• If you have used a representative, and the representative has declared the goods acting as an indirect representative, agree with the representative on which one of you will submit the report.

Information to be reported

The following information must be included in the report: quantity of the imported goods, direct and indirect goods emissions, carbon costs (if any) paid in the country of origin, and the resulting compensations.

The calculation method and reporting method for direct and indirect emissions has been specified in the Commission Implementing Regulation. The information to be submitted in the CBAM reports is listed in Annex I of the Regulation.

How to obtain the emissions data for the report

On its CBAM information site, under Guidance documents, the Commission has published guidance documents to support importers in collecting emissions data from the manufacturers of the goods.

• You can ask the manufacturer to complete the emissions data form (CBAM communication template for installations.xlsx) and to send it to you.
• If you do not get a completed emissions data form from the manufacturer, you can complete the form yourself. Use the Commission’s guidance document (guidance document on CBAM installations for importers of goods into the EU.pdf) as the source.

Please observe that the report can be submitted with insufficient data. If the missing details are not entered within the deadline or if the entire report is missing, a sanction may follow and obtaining the CBAM declarant certificate later may become more difficult.

Where do I report?

The details of the report are submitted to the Commission’s CBAM Transitional Registry system.

• Link and user instructions to the transitional CBAM registry.

Please note that you cannot log in to the system with a Finnish EORI number as yet. We will inform you when that is possible.  

End dates for the report

The annual end dates for the report are 31 January, 30 April, 31 July and 31 October.

---

Reporting during the transitional period plays indirectly an important role in preventing carbon leakage and greenhouse gas emissions.

With the help of the reports, the Commission can establish the default values to be used in calculating the embedded emissions of goods when the definitive period of the CBAM begins in 2026. The reports will also provide important information for assessing the functioning of the mechanism.

The CBAM requires cooperation between importers, manufacturers and authorities and imposes new obligations on importers. To ensure a flexible start, the mechanism begins with a transitional period and a reporting obligation.

The economic impacts of the mechanism are not applied during the transitional period. Instead, traders are given time to adapt to the mechanism as well as an opportunity to organise their reporting practices.

---

The importer must have the authorised CBAM declarant certificate from Customs for submitting annual declarations. The certificate is valid throughout the EU. The certificate can be applied for as of 31 December 2024.

The prerequisites for obtaining the certificate are e.g. the following:

• The applicant is established in a Member State and active mainly within the EU
• The applicant has no outstanding tax debts, no serious or repeated violation of customs or tax legislation or market abuse in the 5 years preceding the year in which the application was submitted
• The applicant does not have any serious economic crimes linked to their operation.
• The applicant has complied with the provisions of the CBAM regulation, e.g. has reported in the required way during the transitional period.

---

The importer must acquire chargeable emissions certificates, i.e. CBAM certificates. The number of certificates required, should correspond to the emissions resulting from goods manufacture. One certificate corresponds to one tonne of embedded emissions of import goods.

There are no restrictions to the number of certificates bought.

The Member States sell the certificates on the Commission’s central platform, and they are automatically registered in a CBAM account, which the Commission establishes for each declarant. The CBAM account must contain at least 80 percent of the quarterly certificate requirement. Certificates that are missing must be acquired within the time limit for lodging the CBAM annual declaration.

The price of the CBAM certificate will be calculated depending on the weekly average auction price of The European Union Emissions Trading System (ETS).  In the spring of 2023, the price of one emission certificate was around 85-90 euros.

Under certain conditions, the Commission buys back no more than a third of the total number of acquired emission certificates.

---

Authorised CBAM declarant status is required for submitting yearly declarations.  

Importers based in the EU can either submit declarations personally or use indirect representatives. If a representative submits a declaration, they must acquire CBAM declarant authorisation.

Importers based outside the EU must use indirect representatives with authorised CBAM declarant status.

Authorised CBAM declarants submit annual declarations to the Commission by 31 May each year. For 2026 imports, the first declaration must be submitted by 31 May 2027. 

• Declaration details: imported goods and direct emissions, as well as the number of required CBAM certificates. 

• The declaration indicates the actual emissions from the goods (default values for imported electricity). If it is not possible to declare actual emissions, default values are provided. 

The CBAM declarant must have a record of the data required for calculating emissions details, and the record must be stored for five years.

The Commission checks the declarations and reports the findings to Customs, who clarifies the matter with the importer.

---

• The implementing regulation regarding the CBAM transitional period was published in the Official Journal of the European Union L 228 on 15th September 2023 and entered into force on 16th September 2023. 
• The Regulation on the Carbon Border Adjustment Mechanism, which has been approved by the European Parliament and Council, was published in the Official Journal of the EU on 16 May 2023, and it entered into force on 17 May 2023. 
• In addition to the EU legislations, national legislation is being prepared and it is expected to enter into force at the beginning of 2024.

---