Advancing the Implementation of the EU Carbon Border Adjustment Mechanism

6. Conclusion

Based on Romania’s case study, the report identifies a number of implementation lessons that may also be relevant across EU Member States, by building on progress achieved to date and addressing remaining gaps. These relate in particular to declarant authorisation, compliance procedures, institutional co-ordination, and the integration of CBAM into customs and administrative processes, and stakeholder support. The report also highlights broader areas that can support effective implementation across the EU, including clarification of technical and financial rules, strengthened institutional capacity, clearer allocation of responsibilities across national agencies, and more structured stakeholder engagement. To effectively implement these recommendations, regularly monitoring and follow-up progress would allow to identify bottlenecks, adjust implementation strategies as needed, and maintain accountability (Recommendation 21).

Recommendation 21: Monitor progress in implementing the recommendations to reap their full benefits

Indicative timeline: Short, medium and long terms

Description: Establishing mechanisms for tracking the progress in the implementation of recommendations is essential to ensure they are fully and effectively carried out. This can be done by adopting a simple monitoring framework, which can include the following modules:

• Recommendation registry e.g., in the form of a table that covers key details such as the number, title, foresee timeline and brief description of the recommendations;

• Accountability and ownership, to clarify who is responsible for implementing each recommendation;

• Implementation status tracker to track progress over time, including information on the current status (e.g., not started, in progress, completed, delayed), milestones achieved, next steps and last updated date;

• Evaluation indicators to regularly assess effectiveness with indicators of success (e.g., data systems integrated, number of meetings held) and feedback loop (i.e. how updates on the implementation of recommendations are shared within NCAs and Customs Authorities and acted upon);

• Risk and issue log detailing identified risks, potential mitigation measures, issues encountered and resolution status.

Monitoring progress can be done by setting up a shared dashboard or tracker accessible to all relevant staff members and centralising and regularly evaluating the above information.