Advancing the Implementation of the EU Carbon Border Adjustment Mechanism

5. Governance and stakeholder support and communication

5.1. Governance

Without a clear long-term strategy for implementing CBAM, uncertainty around roles, responsibilities, and timelines may arise. This risks inefficiencies in the implementation, may increase administrative burdens and can reduces institutional accountability. Fragmented governance across government stakeholders may lead to misaligned policy decisions, challenges in reviewing CBAM data, and delays in processing CBAM tasks. A lack of effective collaboration between key ministries and government agencies, puts compliance with the CBAM Regulation 2023/956 and its secondary legislation at risk and could in the worst-case result in potential trade disruptions or penalties and economic disadvantages for domestic industries and importers exposed to carbon pricing at the EU border.

A robust and well co-ordinated governance framework can greatly strengthen the effective implementation of CBAM across Member States. While involving staff across a broad range of tasks can foster knowledge sharing, flexibility, and institutional learning, as implementation matures, NCAs can further enhance effectiveness by introducing clearer internal structures, well-defined responsibilities, and stronger co-ordination mechanisms with other relevant public authorities. Given the cross-cutting nature of CBAM, regular co-operation with Customs Authorities, EU ETS teams, trade, industry and energy ministries, transmission system operators (TSOs), and other relevant agencies can support more consistent decision making, smoother processing of CBAM-related tasks, and stronger data review capacities.

To support durable implementation, NCAs can adopt clearly defined though flexible governance arrangements that promote efficient information sharing, accountability, and timely decision making (Recommendation 15). This may include specialised teams responsible for key functions such as authorisation of CBAM declarants, CBAM Registry management, CBAM declaration review, legal oversight, and stakeholder engagement, whose missions could evolve over time depending on needs to adapt as the CBAM evolves. Empowering mid-level officials to handle routine decisions can improve responsiveness, while dedicated legal expertise can help ensure continued alignment with EU legislation and management of potential disputes. A strong governance framework can also incorporate risk management procedures to prepare for circumvention risks, regulatory changes, supply-chain disruptions, and other implementation challenges, thereby reinforcing compliance, resilience, and the overall effectiveness of CBAM.

Recommendation 15: Establish a CBAM governance roadmap detailing responsibilities and legal basis for acting

Timeline: Short term

Description: Defining an internal governance roadmap mapping roles and responsibilities and providing the appropriate legal basis for conducting CBAM tasks could support an orderly and successful implementation of CBAM. This could include:

• Identifying main tasks needs and establishing teams within NCAs to perform these distinct tasks. In addition, maintaining a legal advisory team could also prove useful, as it would provide access to specialist expertise and support the resolution of potential disputes;

• Developing a responsibility assignment matrix e.g., a Responsible, Accountable, Consulted, and Informed (RACI) chart for all CBAM-related activities specifying which teams or staff members are responsible to carry out specific tasks, who has to approve the specific outcomes of the tasks, those whose opinions are sought (e.g., subject-matter experts in other agencies), and those who should be keep up to date on progress and completion of the different tasks;

• Incorporating CBAM-related tasks into national legal instruments and/or providing the appropriate legal basis where necessary, in accordance with the CBAM Regulation 2023/956 and its secondary legislation, to minimise the risks of legal disputes. For instance, in order to enable NCAs to impose penalties, it may be necessary to introduce dedicated legal provisions into national law;

  In the longer run, establishing a risk management protocol by defining rapid response processes in the event of major incidents (e.g., massive fraud of one or multiple CBAM declarants) or cyber breaches could prove useful. Responses could be based on potential pre-established administrative procedures already in place.

Effective information sharing and co-ordination across public authorities is also a key component of successful CBAM governance (Recommendation 16). As a cross-cutting instrument, CBAM requires regular collaboration between NCAs, Customs Authorities, and ministries responsible for EU ETS, trade, industry, electricity, and foreign affairs to support coherent implementation, timely problem-solving, alignment with the broader national policy framework, and interoperability with EU-level platforms. Depending on national administrative arrangements, this co-ordination can be supported through permanent or ad hoc interministerial committees – an approach implemented for other topics in Romania (OECD, 2023[1]; OECD, 2024[2]) – as well as interinstitutional agreements or Memoranda of Understanding, which can help clarify roles, strengthen information sharing, and facilitate effective co-operation, particularly between NCAs and Customs Authorities.

Structured stakeholder engagement can inform CBAM governance and strengthen implementation. CBAM affects a wide range of economic actors – including importers, indirect customs representatives, verifiers, upstream and downstream industries, business associations, academic experts, and think tanks – whose experience can help NCAs identify operational bottlenecks, clarify legal and regulatory uncertainties, and refine implementation approaches. In addition to the European Commission’s Informal Expert Group on the CBAM (European Commission, 2024[3]), regular dialogue with these stakeholders can build compliance capacity, improve transparency and trust, and help anticipate unintended consequences such as disproportionate burdens on small and medium-sized enterprises (SMEs) or trade disruptions. This engagement can take different forms, from public consultations and technical workshops to more institutionalised exchanges, such as a CBAM Stakeholder Advisory Group (Recommendation 17).

Recommendation 16: Create a CBAM Interministerial Working Group (IWG) to support communication, information flow and co-ordination across different government agencies

Indicative timeline: Short term

Description: Establishing a CBAM IWG chaired by the NCA could support efficient co-ordination across different government agencies and ameliorate the diffusion of information. It could convene representatives from Customs Authorities, EU ETS NCA, ministries in charge of trade and industrial policy, electricity imports, and foreign affairs, as well as TSOs, national accreditation bodies (NABs), IT and data protection teams.

Meetings could be scheduled on a regular basis at a technical level (e.g., biweekly or monthly), with less frequent meetings at a decision-making level where strategic decisions can be taken (e.g., biannual update on the status of CBAM implementation, draft regulations) and ad hoc sessions for urgent issues such as upcoming changes in EU legislation or major operational incidents.

The CBAM IWG could use a digital platform for sharing information, draft regulations, notifications from the European Commission, and internal procedures.

Recommendation 17: Explore the creation of a CBAM Stakeholder Advisory Group

Indicative timeline: Medium term

Description: Creating a CBAM Stakeholder Advisory Group could offer several strategic advantages that could significantly enhance the quality and effectiveness of its CBAM implementation. The CBAM Stakeholder Advisory Group could convene representatives from relevant businesses, upstream industry operating in CBAM sectors, downstream industry using CBAM goods as inputs, customs and environmental service providers, academic experts, think tanks and members of the CBAM Interministerial Working Group (Recommendation 2). It could be convened on a regular basis (e.g., every quarter or twice a year) or on a case-by-case basis to inform stakeholders of the status of CBAM implementation or potential upcoming changes and gather their feedback.

5.2. Stakeholder support and communication

A responsive and well-structured system for handling stakeholder requests is essential to support effective CBAM implementation and compliance. The complexity of CBAM creates frequent interactions between NCAs and a broad range of stakeholders, particularly as importers and indirect customs representatives navigate reporting obligations, embedded emissions calculations, methodological requirements, IT access, administrative procedures, and application for authorised CBAM declarant status. Given the interdependent nature of these processes, delays or uncertainty in one area can affect the wider implementation process. Establishing an efficient framework to process stakeholder requests in a timely and consistent manner can therefore help reduce bottlenecks, support regulatory compliance, and strengthen trust and transparency throughout CBAM implementation (Recommendation 18).

Recommendation 18: Refine the existing framework for ensuring rapid and efficient processing of requests from stakeholders

Indicative timeline: Medium to long term

Description: Developing a structured processing framework of stakeholders’ requests could help to ensure timely and efficient responses and manage expectations. This could include establishing:

• A request categorisation system to enable more rapid processing via pre-determined assessments and responses for common request. In the longer run, it would allow to implement standardised response templates for common requests, to further streamline processing;

• Internal multi-tier response time targets aligned with the complexity level of the different types of requests. Tier 1 responses (e.g., general information on CBAM and scope inquiries, website resources, existing guidance references) could target shorter response times (e.g., 2 working days). Tier 2 responses (e.g., compliance and enforcement clarifications, IT system access and registry support) could target medium response times (e.g., 5 working days). Tier 3 responses (e.g., technical methodology and emissions calculation questions, complex issues) could target longer response times (e.g., 10-15 working days). If this system proves effective, it would be possible to publish these targets to manage stakeholders’ expectations;

• A digital tracking management of requests and ticket functionality to facilitate the tracking of requests and ensure accountability within the NCA, building on the request categorisation system. Such a functionality could provide automatic acknowledgment of receipt, allow stakeholders to monitor the status of their queries, and implement standardised response templates for common questions;

• A structured phone support service, building upon the existing phone contact. Such system could implement scheduled phone consultation hours with specialised CBAM technical staff for different stakeholder categories (e.g., importers, CBAM declarants, indirect customs representatives, industry and sectoral associations) and maintain integration with written correspondence through the digital tracking management system. Phone support service should complement rather than duplicate written guidance, focusing on interactive problem-solving and clarification of complex scenarios;

• A periodic review of request processing performance to assess the quality and adequacy of responses. This could be done by soliciting feedback from stakeholders requesting assistance (e.g., by including a feedback form in responses) or through the consultation of a particular subset of stakeholders depending on the frequency of the requests.

The processing of stakeholders’ requests could be implemented by a specific response team of one or more staff members (Recommendation 1).

Effective and accessible communication channels are essential to support compliance, reduce administrative frictions, and ensure a smooth CBAM implementation. Given the complexity of CBAM requirements and the diversity of stakeholders involved, NCAs benefit from using a range of communication tools tailored to different needs, from self-service guidance for routine questions to direct expert support for more technical issues. Experience during the transitional period has shown that well-designed communication systems can help prevent delays, reduce confusion around reporting and registry access, and provide more targeted support to stakeholders with limited compliance capacity, including SMEs. Communication strategies should also reflect the international dimension of CBAM, ensuring that information can flow clearly and consistently across complex supply chains involving multiple jurisdictions, intermediaries, and technical actors.

A diversified communication strategy can help NCAs deliver timely, accessible, and efficient support to stakeholders throughout CBAM implementation. Different channels serve different functions and combining these tools in a coherent communication framework can improve clarity, responsiveness, and overall compliance (Recommendation 19).

Recommendation 19: Implement a multi-channel CBAM communication strategy

Indicative timeline: Medium term

Description: NCAs, in co-ordination with Customs Authorities, could implement a multi-channel communication strategy to enhance stakeholder engagement, by ensuring that stakeholders with varying preferences and capabilities can access information and support. The involvement of Customs Authorities would help reach the diverse, and often small, importers falling within the scope of CBAM. This multi-channel communication strategy could include:

• Email and phone support, well suited to complex or case-specific enquiries;

• Newsletters to disseminate regulatory updates, deadlines, and practical reminders;

• Websites and frequently asked questions (FAQs) that allows stakeholders to access guidance independently while reducing administrative burden;

• Social media which help reach smaller firms and amplify key messages

• Webinars and training sessions to support understanding of methodology, registry use, and compliance procedures

• Structured engagement with industry and trade associations to facilitate consistent communication with large stakeholder groups and reduce the volume of individual enquiries, for instance through a CBAM Stakeholder Advisory Group (Recommendation 3).

Clear, up-to-date, and accessible guidance materials are essential to support stakeholder compliance and ensure consistent CBAM implementation (Recommendation 20). Given the technical complexity of CBAM requirements and procedures, comprehensive guidance can reduce reporting errors, improve transparency, and help stakeholders navigate their obligations more effectively. This guidance should be regularly updated to reflect regulatory developments and clarifications, and should combine procedural instructions on key processes, technical explanations of methodological requirements, sector-specific materials tailored to the needs of industries covered by CBAM, and simplified formats – such as presentations or infographics – to improve accessibility, particularly for SMEs and other stakeholders with more limited compliance capacity. The European Commission has developed an extensive library of guidance documents to support CBAM implementation as well as additional guidance in the form of webinars and e-learning modules to address sector-specific aspects of CBAM implementation (European Commission, 2026[4]).

Recommendation 20: Complement EU documentation by developing national guidance to address specific needs of domestic stakeholders

Indicative timeline: Medium to long term

Description: Complementing EU-level documentation by developing domestic guidance could help to address specific and unanswered needs of national stakeholders. This could include:

• Translating key EU documentation where appropriate to make information accessible for stakeholders;

• Developing a national CBAM implementation handbook: NCAs could consider developing an implementation guide that consolidates CBAM requirements with national customs and administrative procedures and documentation requirements, building on EU guidance. This guidance could address common implementation scenarios relevant to national import patterns and industrial sectors and address both direct representation and indirect representation;

• Developing sector-specific implementation handbooks: NCAs could alternatively develop sector-specific guidance materials addressing the needs of importers in key CBAM sectors. Analysis of import data should inform priority sector identification, with sector-specific guidance addressing common products, typical supply chains, and relevant real-world calculation scenarios;

• Developing simplified guidance materials: NCAs could also develop simplified guidance materials specifically addressing the needs of particular stakeholders with limited technical resources e.g., SMEs. These materials could provide step-by-step simplified procedures for scope determination, basic emissions calculation approaches, and CBAM Registry procedures.

References

[4] European Commission (2026), CBAM Guidance and Legislation, https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-guidance-and-legislation_en.

[3] European Commission (2024), Informal Expert Group on the carbon border adjustment mechanism (CBAM) (E03927), https://ec.europa.eu/transparency/expert-groups-register/screen/expert-groups/consult?lang=en&groupID=3927.

[2] OECD (2024), “Co-ordination of green policies at the centre of government in Romania”, OECD Public Governance Policy Papers, No. 45, OECD Publishing, Paris, https://doi.org/10.1787/86439554-en.

[1] OECD (2023), “Coherence and co-ordination at the centre of government in Romania”, OECD Public Governance Policy Papers, No. 34, OECD Publishing, Paris, https://doi.org/10.1787/3feaa33e-en.