Importers - CBAM report by 31 January 2024!

31 January 2024 - important deadline for importers

By 31 January 2024, importers are required to send the first report on high-carbon imports from outside the EU, which include:

• Cement,
• Iron and steel,
• Aluminium,
• Fertilizers,
• Hydrogen,
• Electricity.

Find out which imported goods are subject to CBAM! – List of goods and greenhouse gases subject to the CBAM reporting obligation

The obligation for traders importing goods from the aforementioned groups to file reports is based on the entry into force of parts of the CBAM legislation and the start of the so-called transition period. Learn more: CBAM reporting

CBAM declarations are reports filed quarterly, at the latest by the end of the month following the quarter in which the reportable goods were imported. The first CBAM declarations are submitted by entities for the fourth quarter of 2023, i.e. by the end of January 2024.

Failure to file a CBAM declaration at risk of a fine

The EU's Cross-Border Adjustment Mechanism, the CBAM, came into force on 1 October 2023.

The European Commission's Implementing Regulations not only set out the obligations for importers, but also provide for the possibility of auditing CBAM declarations and the businesses that submit them. The Commission is to inform EU Member States about businesses that fail to comply with their CBAM reporting obligations.

Moreover, if an entity submits a notification in an incorrect manner or presents incorrect or incomplete data, the EC is also obliged to inform the competent authority of the Member State of the irregularities detected.

Entrepreneurs who fail to submit a CBAM declaration can therefore be fined, and the fines already apply during the transition period. According to the Commission's Implementing Regulation 2023/1773, the fines for failure to report greenhouse gas emissions under the CBAM system range from EUR 10 to EUR 50 per tonne of emissions. Ultimately, administrative fines for non-reporting of CBAM in Poland may reach up to PLN 50 000. Such fines are provided for in the EU ETS reporting regulations, on which the CBAM system is modelled.

The national public administrations responsible for CBAM will also carry out checks on the implementation of the CBAM Regulation obligations. Furthermore, the fines are to be indexed for inflation.

CBAM reporting - how can we help?

We have developed a service to provide you with comprehensive support on meeting EU CBAM requirements. Our help covers both preparing your organisation for the new obligations and meeting them during the transition period.

As part of the service - CBAM reporting- we will, inter alia, determine the scope of products covered by CBAM obligations, analyse CBAM obligations for importers and for non-EU suppliers, and prepare quarterly CBAM reports.