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CBAM & customs representation

Matthieu Levasseur
Associate, lawyer, PARADIGMES, France
Published 25 Feb 2026

This presentation explains how the Carbon Border Adjustment Mechanism (CBAM) affects customs representatives and importers, from the scope of covered goods to the practical obligations of an authorized CBAM declarant, and will be of direct relevance to customs and trade compliance professionals handling imports of aluminium, iron and steel, cement, fertilizers, electricity or hydrogen.

Topics covered:

  • Why CBAM was introduced: carbon leakage and the limits of the EU Emissions Trading System
  • The scope of goods covered by CBAM (Annex I) and the planned extension to around 180 additional codes
  • Exclusions for EU-origin goods and goods from Annex III third countries/territories
  • How CBAM obligations differ across direct representation, indirect representation of an EU-established importer, and indirect representation of a non-EU-established importer
  • The DTP codes used on the customs declaration (Y128, Y238, Y137, Y134, Y135, Y422) and the 50-ton de-minimis threshold
  • The four obligations of an authorized CBAM declarant: annual declaration, emissions verification, certificate surrender and minimum quarterly stock
  • The CBAM cost formula, with worked examples for aluminium and aluminous cement imports from China, and how costs are expected to rise towards 2034
  • Sanctions for non-compliance

For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.

Please note that this summary was generated using AI, based on the recording and available slides.

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