New import payment - as of 2026!
CBAM = carbon border adjustment mechanism. This is a new payment for imports of certain goods (over 50t/y) to ensure that it is not more cost-effective to produce goods outside the EU in terms of CO2.
From 2024.
I already wrote about CBAM in 2024, when the relevant EU regulation came into force. The main categories of goods affected are: cement, electricity, fertilizers, iron and metal, aluminum, hydrogen. Annex 1 of the regulation contains a precise list of goods based on their CN codes. Until now, importers had to submit reports on imports of listed goods into the EU using a special CBAM portal. Restrictions and payments do not apply to countries originating in EFTA.
From 2026
Imports - only with authorized CBAM declarants
From 1.1.26, the goods mentioned above may only be imported into the EU by authorized CBAM declarants - the companies themselves or their (indirect customs) representatives. Before importing these goods, the person must submit an application via the CBAM register, providing detailed information about the applicant. The competent authority in the country where the applicant is registered will then grant the status of authorized CBAM declarant if the criteria are met. In Latvia, this application can be submitted to the EDS, and the SRS will review it within 120 days (80 days for A-rated companies). Here is SRS information about these declarants, and here is information about the declarant portal. The 50t volume restrictions do not apply to imports of electricity and hydrogen.
Payments
Importers must also purchase emission allowances (CBAM certificates). The number of CBAM certificates purchased must be equal to the number of greenhouse gas emissions.
One certificate = one ton of emissions related to imported goods.
Member States will sell certificates through a central platform set up by the EC. The price of CBAM certificates is calculated weekly based on the average auction price of European emission allowances. Here is a portal where you can calculate these import costs yourself.
Currently, the price of one emission certificate (changes once a week) is around 85 euros.
Member States will be able to buy back surplus certificates, but the number of certificates bought back cannot exceed 1/3 of the total number of CBAM certificates purchased by the authorized CBAM declarant in the previous calendar year. The OIM payment is also expected to be reduced for carbon taxes paid outside the EU.
Continued:
Example of CBAM cost calculation
Penalties are also envisaged
Practical impact
