The Carbon Border Adjustment Mechanism is a core element of the European Union’s climate strategy under the European Green Deal and Fit for 55 package. It aims to mitigate carbon leakage by applying to selected imported goods a carbon price equivalent to that faced by domestic producers under the EU Emissions Trading System (ETS). In doing so, it aims at tackling carbon leakage and supporting the EU’s goal of reducing net greenhouse gas (GHG) emissions by at least 55% by 2030, compared with 1990 levels and achieving climate neutrality by 2050.
The CBAM entered its definitive period on 1 January 2026 after transitional implementation from 1 October 2023 to 31 December 2025. The definitive period introduced stricter obligations including annual reporting, mandatory third-party verification, and the purchase and surrender of CBAM certificates, in parallel with the gradual phase-out of EU ETS free allowances for CBAM-covered sectors.
Drawing on Romania’s case study, the report identifies several challenges related to the implementation of CBAM and proposes ways to address them and support its successful implementation. The analysis covers legal changes and policy refinements up to July 2026. Table 1, at the end of the Technical Summary,
Table 1 summarises the recommendations based on the assessment in the report. Within this broader set of recommendations, several specific implementation priorities emerge for CBAM national competent authorities (NCAs) and customs authorities. These include clarifying CBAM processes such as authorising CBAM declarants (Recommendations 2 and 3), determining guarantee requirements (Recommendation 4), imposing penalties (Recommendation 8) and advancing customs integration through interoperable IT systems (Recommendation 12), robust risk management tools to prevent circumvention (Recommendation 13), and alignment of CBAM authorisation processes with existing trade facilitation programmes (Recommendation 14).
Delivering on these operational priorities will require a broader set of institutional, technical and coordination measures. These include strengthening NCAs and Customs Authorities’ capacity and technical readiness (Recommendations 1 and 10), clarifying responsibilities (Recommendations 15) and developing national guidance to perform tasks (Recommendations 4, 5, 6, 8, 9 and 10), supported by the use of digital tools (Recommendation 7). In addition, stronger coordination and communication across government agencies and private CBAM stakeholders (Recommendations 16, 17, 18, 19 and 20) will be essential. This could include ensuring strategic alignment and efficient information sharing, potentially through formal coordination mechanisms. Continued close collaboration with the European Commission and with NCAs and customs authorities in other Member States will also be key to facilitating domestic implementation, harmonising practices and avoiding fragmentation in the implementation of CBAM.