CBAM & customs representation

Matthieu Levasseur
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.

Related content

CBAM liability of importers and ‘other persons’

CBAM liability of importers and ‘other persons’

Michael Lux
Michael Lux
21 Dec 2025

The CBAM Regulation distinguishes as of 1 January 2026 between importers or their customs representatives who are ‘authorised CBAM declarants’ declaring CBAM goods for release for free circulation, and 'other…

Sustainability
Topic spotlight
EU & UK CBAM explained: key developments and practical implications for traders

EU & UK CBAM explained: key developments and practical implications for traders

Jan-Joost den Brinker
Jan-Joost den Brinker
29 Jun 2026

A practical, technically detailed session on EU CBAM (Carbon Border Adjustment Mechanism) and the forthcoming UK CBAM, comparing how the two regimes are structured and where importers, suppliers and customs…

Sustainability
CBAM goes downstream: what importers of steel and aluminium goods must do before 2028

CBAM goes downstream: what importers of steel and aluminium goods must do before 2028

Erika Besusparienė
Erika Besusparienė
02 Aug 2026

Importers that have only recently adapted to CBAM on raw steel and aluminium now face a further change. The Council's general approach of 12 June 2026 would extend the carbon…

Sustainability
Topic spotlight
EU deforestation regulation - ensuring compliance and gaining competitive advantage

EU deforestation regulation - ensuring compliance and gaining competitive advantage

Mindaugas Ganusauskas
Mindaugas Ganusauskas
04 Nov 2025

This training webinar breaks down the EU Deforestation Regulation (EUDR) into practical, actionable steps, making it directly relevant to customs and trade compliance professionals who import, export or place regulated…

Sustainability
Understanding CBAM: what importers need to know before 2026

Understanding CBAM: what importers need to know before 2026

Peter Špirec
Peter Špirec
26 Oct 2025

A practical walkthrough of CBAM (Carbon Border Adjustment Mechanism) import readiness for 2026, aimed at customs and trade compliance professionals who need to understand what changes for importers as the…

Sustainability
EU and UK CBAM: Key differences, future risks and compliance challenges

EU and UK CBAM: Key differences, future risks and compliance challenges

Marcel Duits
Marcel Duits
09 Sep 2025

A practical, comparative briefing on the EU and UK Carbon Border Adjustment Mechanisms (CBAM), presented by Marcel Duits, Chief CBAM Officer at Dubrink, for customs and trade compliance professionals managing…

Sustainability