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Navigate CBAM With Confidence: TÜV Rheinland Compliance Services

Navigate CBAM With Confidence: TÜV Rheinland Compliance Services

What is the Carbon Border Adjustment Mechanism (CBAM)?

CBAM is the European Union’s mechanism to price carbon emissions associated with certain imported goods. It ensures fair competition between EU-based manufacturers and importers from countries with less stringent climate policies. In May 2023, the European Commission introduced the Carbon Border Adjustment Mechanism (CBAM). The CBAM is a second emissions trading system for importers and represents the first border adjustment for CO2 prices worldwide.

CBAM is not just regulation—it's a strategic imperative for global trade."

Global Carbon Expert

The CBAM requires EU companies importing certain products from non-EU countries to determine the CO2 emissions contained in these imports and then purchase a corresponding number of CBAM allowances. In this way, imports from non-EU countries will be charged the same CO2 price as if they had been produced in the EU.

As of 2025, CBAM reporting becomes mandatory, with certificate surrender obligations beginning in 2027.

Who is Affected by CBAM?

  • Importers of iron, steel, aluminum, fertilizers, hydrogen, electricity, and cement into the EU.
  • Companies with non-EU manufacturing partners subject to embedded carbon cost considerations.
  • Businesses needing to adapt their carbon cost reporting and procurement strategies to remain CBAM-compliant.

What does CBAM mean for your business?

Watch our experts Dr. Bahar Cat-Krause and Hritik Patil explain the key challenges and opportunities in this short interview

Key CBAM Updates for 2025

Here you can find the main topics that are affected by the update. Please click on the tiles for further information.

Delegated Reporting & Anticircumvention
Deferred Certificate Obligations
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Delegated Reporting & Anticircumvention

From 2025, importers can delegate their CBAM reporting obligations to third-party service providers, while remaining responsible for the accuracy of the information. At the same time, stricter anti-circumvention rules prevent attempts to bypass the system, such as relabeling goods or routing them through third countries.

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Deferred Certificate Obligations

CBAM certificates will be required starting in 2027, while carbon pricing will already apply from 2026, allowing importers a transitional period before full certificate obligations take effect.

Extended Reporting Deadlines
Flexible Emissions Data Options
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Extended Reporting Deadlines

The deadline for submitting annual CBAM reports has been extended to August 31 for the year following the reporting year, effective from 2026 onwards, giving importers additional time to verify their data, ensure accuracy, and complete the submission process. This extension helps reduce administrative pressure and supports more reliable reporting.

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Flexible Emissions Data Options

Importers have the flexibility to report their emissions using either actual measured data or the default EU values. This approach allows companies to choose the method that best fits their data availability and reporting capabilities, while ensuring compliance with CBAM requirements.

Simplified Deductions
New Mass-Based Exemption
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Simplified Deductions

Importers can deduct carbon costs already paid abroad by applying EU-approved default rates. This simplified approach makes it easier to account for foreign carbon pricing while ensuring consistency and compliance with CBAM rules.

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New Mass-Based Exemption

The previous €150 per shipment exemption has been replaced with a new mass-based threshold of 50 tonnes per year. This change reduces reporting obligations for small importers, making compliance simpler and more proportionate to the volume of goods imported.

How Can Your Business Prepare for the New CBAM Requirements?

To stay compliant and competitive, companies should take proactive steps to adapt to the CBAM:

  • Review your supply chain emissions data collection processes.
  • Assess carbon cost impacts and adjust financial planning accordingly.
  • Consider third-party CBAM reporting solutions for easier compliance.
  • Engage with carbon cost verification services to optimize deductions.

By acting early, businesses can not only ensure compliance but also strengthen their position in a more carbon-conscious market.

How can TÜV Rheinland help you?

Meeting the CBAM requirements can be complex, from emissions monitoring to preparing for future certificate surrender. TÜV Rheinland supports you with expert services to make compliance seamless:

  • Technical Support: Guidance on the latest CBAM obligations, emissions monitoring, and accounting methodology.
  • Training: Equip your team with the knowledge needed to verify emissions data and manage carbon cost deductions effectively.
  • Pre-verification: A proactive check of your business operations and reporting to ensure readiness for CBAM certificate surrender in 2027.

Navigate CBAM With Confidence: TÜV Rheinland Compliance Services

If you import iron, steel, aluminum, fertilizers, cement, electricity, or hydrogen into the EU, you are subject to CBAM regulations. Businesses outside the EU with EU-based customers must also prepare for carbon cost transparency. Get in touch with our CBAM experts today to discuss how TÜV Rheinland can support you in staying compliant and competitive.

Flyer: Carbon Border Adjustment Mechanism (CBAM)

Flyer: Carbon Border Adjustment Mechanism (CBAM)

CBAM 2025 Updates: Key Changes, Impacts and What your Business Needs to Know for you to download in one file.

Frequently Asked Questions About CBAM

Quick answers to help your compliance journey.

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Why is CBAM being implemented?

The EU is implementing CBAM to address the risk of carbon leakage due to harmonized greenhouse gas emission pricing within the EU.

What goods are covered by CBAM?

Initially, CBAM applies to iron, steel, aluminum, cement, fertilizers, electricity, and hydrogen.

How will CBAM impact importers?

Importers will need to report the emissions associated with their products and may have to pay a carbon price equivalent to that of EU producers.

When do financial obligations begin?

CBAM certificates must be surrendered starting 2027. Pricing starts from 2026.

Can I delegate CBAM reporting?

Yes, reporting can be assigned to authorized third-party representatives.

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