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

The Carbon Border Adjustment Mechanism (CBAM) is a new instrument of the EU for preventing carbon leakage, that is, release of emissions to regions outside the EU. The Carbon Border Adjustment Mechanism is an element of Fit for 55 package for European green development.

The Mechanism is applied to certain products specified in an EU Regulation. When CBAM products are imported to the customs territory of the EU from outside the Union, from the start of 2026 importers are obliged to

• obtain CBAM certificates in a number corresponding to emissions resulting from goods manufacture
• submit yearly CBAM declarations to the Commission.

Importers are not yet required to obtain CBAM certificates during the transition period lasting from 1 October 2023 to 31 December 2025. However, importers are required to submit quarterly reports to the Commission. See detailed instructions on schedules for importers of CBAM products on this page.

About the terms

In the public debate, the terms “carbon duty” and “carbon tax”, for example, have also been used for the Carbon Border Adjustment Mechanism. However, these terms are no longer used, because it is not a question of a customs duty or tax, but of a CBAM certificate subject to a charge.

Who do the new obligations concern?

The obligation to submit reports during the transition period and to obtain CBAM certificates concerns all private individual and businesses who import CBAM products. 

Schedule for importers of CBAM products:

1. Reporting during the 2023-2025 transitional period

   • The transition period starts on 1 October 2023 and ends of 31 December 2025. Importers or their representatives submit quarterly reports on CBAM products to the Commission. The first report must be submitted by 31 January 2024. This report covers the information for the period from 1 October to 31 December 2023.

   • Report details: quantity of the imported product, direct and indirect product emissions, carbon costs in the country of origin, and the resulting compensations. 

2. Annual reporting starts with imports for 2026   

   • 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 products and direct emissions, as well as the number of required CBAM certificates. 

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

   • Accredited verifiers will confirm the information in CBAM declarations.

Legislation underway

EU legislation and national legislation regarding the Carbon Border Adjustment Mechanism is under preparation. It is estimated that national legislation takes effect on 1 January 2024.

Customs suggested as the competent authority 

Customs is the suggested competent authority in Finland in accordance with the CBAM regulation. For example, Customs would advise businesses, grant authorisations to CBAM declarants and sell CBAM certificates.

At the ministerial level, CBAM is the responsibility of the Ministry of Economic Affairs and Employment.

More information  

• Ministry of Economic Affairs and Employment 24.1.2023: Working group to prepare national implementation of Carbon Border Adjustment Mechanism