Advancing the Implementation of the EU Carbon Border Adjustment Mechanism

4. Role of Customs Authorities

Customs Authorities play a central role in CBAM implementation. They ensure compliance through border checks and by sharing import data with the NCA and the European Commission (Sections 4.1 and 4.2). The CBAM-related responsibilities for Customs Authorities require a clear sequence of checks and the use of specific data elements and IT systems.

Applying a trade facilitation lens helps identify potential risks of disruption and administrative burden at the border stemming from the implementation of CBAM (Section 4.3). At the same time, a trade facilitation perspective highlights opportunities to efficiently integrate CBAM-related procedures into overall customs and border procedures.

4.1. Customs procedures and information systems

The implementation of CBAM introduces new and complex responsibilities for government authorities across the EU. While the legal framework is defined at EU level set out in the CBAM Regulation 2023/956 and accompanying implementing regulations and coordinated by the European Commission its effective implementation depends on the institutional and operational capacity of national authorities. Governments are tasked with establishing and integrating CBAM-specific procedures involving two key authorities: the newly created NCAs (Part 3) and Customs Authorities. As the CBAM timeline moves further into the implementation phase, EU Member States must align their procedures, secure adequate human resources, upgrade technical infrastructure, and enhance inter-agency cooperation to ensure effective enforcement while minimising administrative burden and costs.

Customs Authorities play a central role in the CBAM implementation framework, notably in enforcing border procedures and related data transmission. They oversee the movement of all goods crossing national borders, including those covered by the CBAM Regulation: iron and steel, cement, fertilisers, aluminium, electricity, and hydrogen. As the first point of entry at all land, sea, and water borders, customs receive and assess key trade information on the customs declaration, such as the identity of the importer, the type and quantities of imported goods, and their value and origin. In the CBAM context, customs act as a central link between the CBAM declarants (importers or indirect customs representatives), NCAs, and the European Commission (Figure 4.1).

The institutional setup for CBAM implementation varies across EU Member States, reflecting different national approaches to climate, tax, and trade governance. Member States have located NCAs in environmental agencies or ministries responsible for the EU ETS, or the NCA sits between finance ministries and Customs Authorities (typically situated within the Ministry of Finance). These differing setups come with varying levels of policy coordination and integration for instance, with respect to the formalisation of coordination across authorities, the type and frequency of exchanges, and integration within existing Single Window systems.

Figure 4.1. CBAM actors and procedures relating to Customs Authorities

Source: Authors, based on CBAM Regulation 2023/956

The CBAM Regulation 2023/956 details Customs Authorities’ responsibilities in several areas, including enforcement at the border and associated checks, inter-agency communication, and additional duties such as assistance to the European Commission in detecting circumvention and informing importers (Table 4.1). Article 25(1) foresees that customs are responsible for ensuring that only authorised CBAM declarants import CBAM-covered goods. Customs Authorities also play a critical role in sharing relevant data with the European Commission and NCAs, cooperating with other authorities, informing importers, and investigating circumvention. While the CBAM Regulation lays out the general tasks of Customs Authorities, the European Commission has been developing further implementing acts and amendments expected to define customs' responsibilities.

Table 4.1. Customs Authorities' tasks under the CBAM Regulation 2023/956

Task	Customs responsibilities	Legal reference in CBAM Regulation 2023/956
Enforce the regulation at the border and carry out related checks	Ensure that only authorised CBAM declarants are allowed to import goods covered by the CBAM Regulation Carry out checks on CBAM goods, including with respect to the identification of the authorised CBAM declarant, the eight-digit CN code, the quantity and the country of origin of the imported goods, the date of declaration and the customs procedure	Article 25(1) and Recital 43
Communicate relevant information (European Commission and NCA)	Periodically and automatically communicate information to the European Commission (by means of the EU surveillance mechanism) on the goods declared for importation (EORI number of the authorised CBAM declarant, CBAM account number of the authorised CBAM declarant, eight-digit CN code of the goods, quantity, country of origin, date of the customs declaration, customs procedure) Periodically and automatically communicate to the European Commission information on imported goods (by means of the EU surveillance mechanism or by electronic means of data transmission), including processed products resulting from the outward processing procedure (EORI number of the customs declarant and of the importer, the eight-digit CN code, the quantity, the country of origin, the date of the customs declaration and the customs procedure) If applicable, communicate confidential information to the European Commission and to the NCA of the Member States that has granted the status of the authorised CBAM declarant	Article 25(2), 33(2) and 25(4)
Assist the European Commission (circumvention)	If applicable, assist the European Commission in investigating practices of circumvention of the CBAM Regulation	Article 27(5)
Inform importers	Inform the importer (or the indirect customs representative) of the CBAM reporting obligation no later than at the moment of the release of goods for free circulation During the transitional period, inform customs declarants in an appropriate manner of the obligation to report information and to request the status of authorised CBAM declarants where applicable	Article 33(1) and Recital 44

Source: Authors, based on the CBAM Regulation 2023/956

4.2. Enforcing CBAM at the border and carrying out related checks

Customs Authorities are responsible for enforcing the CBAM Regulation at the border. Under Article 25(1) of the CBAM Regulation 2023/956, they must ensure that only authorised CBAM declarants import CBAM-covered goods. In line with Recital 43, they carry out checks on CBAM goods covering the identification of the authorised CBAM declarant, the eight-digit CN code, the quantity and country of origin of imported goods, the date of declaration, and the customs procedure.

With the definitive period applying from 2026, Customs Authorities should strengthen operational capacity to automate customs data transfers, introduce checks to verify CBAM authorisations, and integrate CBAM-related factors into customs risk management (Recommendation 10).

Recommendation 10: Strengthen Customs Authorities operational capacity for implementing CBAM

Indicative timeline: Short term

Description: Customs Authorities should continue strengthening their capacity to ensure that customs processes, IT systems, and staff capacity are fully aligned with EU requirements. This could involve:

• Conducting internal mapping and gap analysis: review procedures, data requirements, IT infrastructure, and resources for CBAM tasks, identifying operational, technical, and capacity gaps, with special focus on high-volume and high-risk entry points;

• Defining contact points, cooperation arrangements, and responsibilities: establish a dedicated CBAM contact point, enhance cooperation with the NCA, and set clear responsibilities, contact persons, and timelines across Customs offices;

• Enhancing technological readiness and risk management: enable SURV3-based data transfers, implement automated CBAM authorisation checks, and integrate CBAM-specific risk profiles into automated risk analysis and its integration with EU systems (such as for the misclassification of CBAM goods);

• Developing operational guidance and deliver training: produce detailed CBAM guidance for customs officers and deliver structured, case-based training on compliance checks, TARIC use, data transmission, and risk-based controls.

When a customs declaration is submitted, three questions are central: Is the imported good covered by CBAM? Does CBAM apply given the customs procedure and any exemptions? Is the importer an authorised CBAM declarant? Customs therefore follow a structured sequence of checks, summarised in Figure 4.2, and developing guidance on processes to enforce CBAM at the border is recommended (Recommendation 11). The Single Administrative Document (SAD) is the EU's standard customs declaration form for imports, exports, and transit. It contains up to 54 boxes detailing information such as origin, classification (CN code), value, and customs procedure. While based on a paper layout, it is mostly submitted electronically via national systems aligned with the Union Customs Code (UCC).

Figure 4.2. Customs sequence of checks to enforce CBAM at the border

Source: Authors.

4.2.1. Step 1: Determine if the good is CBAM-covered

Customs need to identify accurately which imports are subject to CBAM. They check the CN code (in Box 33 of the SAD), the country of origin, the value/quantity of CBAM goods, and the customs procedure on the customs declaration. If the CN code matches a code listed in Annex I of the CBAM Regulation, the product is classified as a ‘CBAM good’. Electricity imports are a special case (Box 4.1). The country of origin is determined according to the non-preferential rules of origin (Article 60(2) of Regulation 952/2013 and Article 32 of UCC Delegated Act 2015/2446).

Box 4.1. Customs procedures for imports of electricity as a CBAM good

Although electricity is not a physical good, it is classified under CN code 2716 00 00 in Annex I of the CBAM Regulation, making it subject to CBAM obligations. To identify electricity imports, Customs Authorities check customs declarations submitted by the party to whom transmission capacity has been allocated, typically a market participant regarded as the authorised CBAM declarant. Customs may perform additional document checks to verify the correctness of declarations and ensure compliance, including commercial contracts (power purchase agreements) to confirm the legitimacy of the transaction; confirmation from transmission system operators (TSOs) regarding the physical delivery of electricity through interconnectors; and metering data to validate the quantities imported.

Source: European Commission (2025[1]).

4.2.2. Step 2: Determine if CBAM applies (customs procedure and exemptions)

Customs Authorities need to check the customs procedure assigned to imported goods, identified by a Customs Procedure Code (CPC) in Box 37 of the SAD. Five customs procedures are relevant for CBAM:

• Release for free circulation: If goods are imported for final consumption, CBAM applies (Articles 3(4) and 4 of the CBAM Regulation 2023/956);

• Inward processing: If non-EU goods are placed under inward processing (e.g., imported for manufacturing or repair without paying import duties), CBAM does not apply. However, if the CBAM good is eventually released for free circulation, CBAM applies (Article 2(1) and Article 6 of Implementing Regulation 2023/1773);

• Outward processing: Where EU goods are exported for further processing abroad and re-imported, CBAM reporting applies only to emissions generated during the external processing (Article 6(4) of the CBAM Regulation 2023/956);

• Returned goods relief: Goods exempted under Article 203 of the UCC are declared with zero embedded emissions and are CBAM-exempt (Article 6(5) of the CBAM Regulation 2023/956). For returned goods originally re-exported after inward processing (Article 205 of the UCC), CBAM reporting obligations apply;

• Temporary admission/transit: Goods imported temporarily and re-exported within a defined time are not released for free circulation and thus not subject to CBAM.

Customs also check whether exemptions or derogations apply to specific goods or origin countries. The TARIC database supports accurate classification through CN codes (Box 4.2). Exemptions under the CBAM Regulation 2023/956 (as amended by the amending Regulation 2025/2083) apply in the following cases:

• Goods used in military activities (Article 2(3));

• Electricity generated on the continental shelf or in the exclusive economic zone of a Member State (Article 2(3)a);

• Hydrogen originating on the continental shelf or in the exclusive economic zone of a Member State (Article 2(3)a);

• De minimis exemption i.e. single mass-based threshold initially set at 50 tonnes per calendar year not applying to electricity and hydrogen (Article 2a).

Exemptions also apply for specific non-EU countries and territories under Annex III: Iceland, Liechtenstein, Norway, Switzerland; and special territories Büsingen, Heligoland, Livigno, Ceuta, and Melilla.

Box 4.2. Using TARIC document codes for automatic customs clearance of CBAM goods

TARIC, the Integrated Tariff of the European Union, is a multilingual database integrating all measures relating to EU customs tariff, commercial, and agricultural legislation. Daily electronic transmissions of TARIC data feed national customs clearance systems, maximising automatic clearance.

TARIC document codes are alphanumeric identifiers that supplement CN codes to reflect legal requirements beyond tariff classification, covering licences, certificates, or special conditions (such as anti-dumping duties or, in the CBAM case, financial adjustment obligations). They guide automated decision-making in customs clearance systems.

Y-codes are document codes used in customs declarations to indicate regulatory requirements that must be fulfilled at import (Box 44 of the SAD). Within CBAM, Y-document codes translate the legal provisions of Article 25 of the CBAM Regulation 2023/956 into machine-readable customs logic. In December 2025, the European Commission published a document explaining the document codes for CBAM, notably including:

• Y128: CBAM account number (of the authorised CBAM declarant, in accordance with article 16(1) of the CBAM Regulation 2023/956);

• Y134: Goods originating in Büsingen, Heligoland, or Livigno (Article 2(4) of the CBAM Regulation 2023/956);

• Y135: Exemption by virtue Article 2(3) of the CBAM Regulation 2023/956 (goods to be moved or used in military activities);

• Y136: Exemption by virtue Article 2(3)a. of of the CBAM Regulation 2023/956 (electricity generated or hydrogen originating in the exclusive economic zone or on the continental shelf of a Member State (for 2804 10 00 and 2716 00 00);

• Y137: Exemption by virtue Article 2a. of Regulation (EU) 2023/956 (de minimis exemption not applicable for electricity and hydrogen);

• Y237: Goods of EU origin;

• Y238: Application to obtain the status of authorised CBAM declarant has been submitted until 31 March 2026 (foreseen until 27 September 2026, time limit for the procedure).

Source: European Commission (2025[2]; 2024[3]; 2025[4]).

Customs Authorities also need to check the revised de minimis exemption under the amending Regulation 2025/2083, which exempts declarants importing less than 50 tonnes of CBAM goods per year. Importers below this threshold self-identify as ‘occasional CBAM importers’ when lodging customs declarations and monitor their cumulative annual imports. They are exempted from CBAM authorisation, declaration, and certificate obligations. Compliance is monitored by the European Commission and NCAs based on customs data, with anti-abuse provisions and regular reviews planned from 2027. The exemption does not apply to electricity and hydrogen. Customs Authorities are responsible for providing the necessary data to the NCA. Where an NCA concludes that an importer has exceeded the threshold, customs should block further imports from that importer until the end of the calendar year or until the importer obtains authorised CBAM declarant status (Recital 9 of the amending Regulation 2025/2083).

4.2.3. Step 3: Verify CBAM authorisation

If imported goods fall under the CBAM Regulation, customs verify that the importer is an authorised CBAM declarant. When products are identified as CBAM goods and CBAM applies, customs check that the NCA has granted authorisation (Section 3.1). They can refer to the CBAM Account Number, a unique identifier assigned by the European Commission to authorised importers. The CBAM Account Number gives access to the CBAM Registry and is also reflected via a Y-code in the customs declaration (Box 4.2).

Recommendation 11: Develop a step-by-step customs process for CBAM compliance checks

Indicative timeline: Short term

Description: Customs Authorities should develop detailed guidance on a step-by-step process to enforce CBAM at the border. This includes:

• Accurately identifying CBAM goods: Use CN codes and country of origin to identify CBAM-covered goods. Electricity imports may require additional checks (e.g., power purchase agreements, metering data);

• Assessing CBAM application: Verify if CBAM applies based on customs procedure codes and relevant exemptions (e.g., special territories, personal luggage, military goods) automatically using TARIC Y-codes;

• Verifying authorisation: Check if the importer is authorised as CBAM declarant by NCAs by using the CBAM Account Number in the CBAM Registry and the corresponding Y-codes included in the customs declaration;

• Monitor the de minimis threshold: Identify occasional importers under the de minimis threshold, support monitoring with NCAs and the European Commission, and restrict imports when thresholds are exceeded.

4.2.4. Communicating relevant information via data transmission mechanisms

Customs Authorities play an important role in providing detailed import data to the European Commission and NCAs. Under Articles 25(2) and 33(2) of the CBAM Regulation 2023/956, they must periodically and automatically communicate information on goods declared for importation ideally using the EU customs surveillance mechanism (Box 4.3) or other electronic means. This includes the EORI number and CBAM Account Number of the authorised declarant, the eight-digit CN code, quantity, country of origin, customs declaration date, and customs procedure used (Table 4.2). Information on processed products resulting from outward processing must also be communicated.

Box 4.3. The EU Customs Surveillance System and its role in CBAM enforcement

The EU Customs Surveillance System (SURV) is a centralised electronic platform operated by the European Commission to monitor imports and exports across Member States. Established under Article 55 of Implementing Regulation 2015/2447, it ensures uniform application of the UCC and supports risk analysis, tariff quota management, and regulatory compliance.

The current version, SURV3, mandated under Article 100 of Implementing Regulation 2025/512, enables automated, near-real-time transmission of 57 standardised customs data elements, including the eight-digit CN code, quantity, country of origin, customs procedure code, date of declaration, and EORI numbers. Data is transmitted from national customs systems to the European Commission, typically daily.

Under Recital 8 of Implementing Regulation 2024/3210 on the CBAM Registry, SURV3 must be interconnected with the CBAM Registry to retrieve customs data for CBAM-covered goods, enabling CBAM risk assessment, compliance checks, and circumvention monitoring.

Table 4.2. CBAM data elements and systems relevant for Customs

Data element or system	Existing/new	Use in CBAM enforcement
EORI number	Existing customs declaration	Identifies the CBAM declarant and links to their account
Eight-digit CN code	Existing customs declaration	Determines whether goods fall under CBAM scope (Annex I of the CBAM Regulation 2023/956)
Quantity of goods	Existing customs declaration	Used for emissions calculation and certificate surrender obligations.
Country of origin	Existing customs declaration	Assesses whether an exemption applies under Article 2 of the CBAM Regulation 2023/956
Date of customs declaration	Existing customs declaration	Determines reporting period for CBAM declaration and compliance
Customs Procedure Code (CPC)	Existing customs declaration	Determines whether CBAM applies (e.g., CPC 40 00)
CBAM account number (code Y128)	New data field relating to CBAM in existing Customs declaration	Determines whether the importer has the authorised CBAM declarant status
Occasional CBAM declarant status	New data field relating to CBAM in existing customs declaration	To indicate the de minimis threshold of 50-tonne mass
SURV3 (UCC Surveillance System)	Existing system	Transmits customs data for CBAM monitoring and enforcement
TARIC	Existing system	Supports classification and identification of CBAM goods
CRMS2	Existing system	Used for risk profiling and control selection related to CBAM imports
EU Single Window Environment for Customs (EU CSW-CERTEX)	Existing system, in the early stages of implementation(1)	To facilitate data transmission between Customs Authorities and CBAM Registry/NCAs. The CBAM Registry is not yet fully connected to the EU SWE-C but its integration is planned (Article 5(2) of the Implementing Regulation 2024/3210 requires for the CBAM Registry to enable digital cooperation with the EU SWE-C)
CBAM Registry	New for CBAM	Stores all CBAM declarants, emissions, and certificate information

Note: (1) The implementation is phased and ongoing. The first phase, focusing on Government-to-Government data transmission, became operational in March 2025; the Business-to-Government component is scheduled for 2031 (European Commission, 2025[5]).

Source: Authors, based on the CBAM Regulation 2023/956 and the amending Regulation 2025/2083.

Most CBAM-relevant data elements are already collected through existing customs procedures, however, the CBAM framework introduces new data points. Customs Authorities collect import data from customs declarations, which are a prerequisite for NCAs and the European Commission to identify importers and enforce CBAM obligations, including emissions reporting, certificate surrender, and penalties. The CBAM Regulation introduces new data elements such as the CBAM Account Number and the declarant authorisation status, which customs must verify (Table 4.2).

The CBAM rollout also introduces new systems. This includes the CBAM Registry, a standardised electronic platform containing data on authorised CBAM declarants and their certificates that enables real-time data transmission and verification. Using automated and harmonised data transmission tools can ensure an efficient enforcement of CBAM (Recommendation 12).

Recommendation 12: Integrate electronic data transmission mechanisms and digital tools for CBAM tasks

Indicative timeline: Short term

Description: Customs Authorities should use automated and harmonised data transmission with the European Commission and NCAs to ensure efficient CBAM enforcement. This involves:

• Collect and verify accurate and complete CBAM-relevant import data: Identify and integrate relevant data elements pertinent for CBAM including the authorisation status of CBAM declarants by the NCA and the CBAM account number;

• Ensure regular and automatic transmission of import data to the NCA and the European Commission (EORI number, eight-digit CN code, quantity of goods, country of origin, date of customs declaration, CBAM account number);

• Integrate with common data platforms: Ensure interoperability of national customs IT systems with the EU CBAM Registry, the EU Customs Surveillance System (SURV3), and the EU Single Window Environment for Customs (EU CSW - CERTEX);

• Integrate CBAM guidance and communications into national platforms and customs IT portals, embedding instructions directly into electronic customs declaration systems.

4.2.5. Additional responsibilities

Customs Authorities also assist the European Commission in investigating CBAM circumvention practices under Article 27(5) of the CBAM Regulation 2025/956. Recital 66 identifies several forms of circumvention:

• Slight modification of goods to change their classification without altering essential characteristics;

• Artificial splitting of shipments to avoid CBAM thresholds or obligations;

• Transshipment through third countries to obscure the true origin of goods;

• Reorganisation of patterns and channels of sale and production to bypass CBAM enforcement;

• Dual production and dual sale practices with parallel product lines for different markets;

• Any other practices intentionally aimed at evading CBAM obligations.

Customs may also carry out checks under Article 46 of the UCC, allowing them to stop, inspect, and investigate imports where CBAM fraud is suspected. The CBAM Registry is intended to be interconnected with the Customs Risk Management System (CRMS2), allowing Customs Authorities to exchange risk alerts and analyse inspection results from other Member States. The European Commission is expected to include CBAM-related risks in the establishment of common risk criteria and standards (Recital 43).

The European Commission relies on data and alerts from national Customs Authorities to identify risks and monitor circumvention at EU level. SURV3 and CRMS2 work in tandem: SURV3 provides detailed trade data (quantities, CN codes, origin, values) that can be analysed to detect anomalies. Emerging patterns can trigger alerts or risk profiles in CRMS2, which are then shared across all EU Customs Authorities to enable coordinated responses. A feedback loop is also in place: operational insights from CRMS2 (inspections, seizures, confirmed circumvention attempts) inform ongoing SURV3 analysis. Strengthen customs risk management would help to detect and prevent CBAM circumvention (Recommendation 13).

Recommendation 13: Strengthen customs risk management to detect and prevent CBAM circumvention

Indicative timeline: Short to medium term

Description: Customs Authorities need to address potential attempts to bypass the CBAM, such as falsifying goods classification, artificial splitting of shipments, disguising true origin/ producers of goods or falsifying carbon emissions data. They should prioritise and adapt risk management systems to detect and prevent CBAM circumvention by:

• Conducting comprehensive risk assessments focused on CBAM circumvention patterns using customs data analytics;

• Aligning national customs risk management protocols with the EU Customs Reform initiatives, ensuring seamless integration with the EU CRMS2 for coordinated risk profiling;

• Collaborating with NCAs and the European Commission to develop and update CBAM-specific common risk criteria.

Finally, Customs Authorities play a role in informing importers or indirect customs representatives about their CBAM obligations. Under Article 33(1) of the CBAM Regulation 2023/956, customs must inform the importer of the CBAM reporting obligation at the moment of release for free circulation. They are also expected to inform about the need to request authorised CBAM declarant status during the transitional period (Recital 44). Customs are free to choose the form of this communication.

4.3. Trade facilitation perspective

Trade facilitation measures are essential for ensuring that trade flows are both smooth and safe. They streamline and simplify technical and legal procedures for products at the border. The implementation of sustainability-related regulations raises new questions in today's context, where the regulatory environment for the digitalisation of trade documents and processes (going paperless) matters for facilitating border procedures. This includes what new documents may be needed, how they relate to existing trade processes, and how commercially sensitive information is protected. Trade facilitation policies, including digital tools, can create synergies between trade compliance procedures and the streamlining of border processes (OECD, 2025[6]).

Trade facilitation measures span the full spectrum of border procedures. The OECD has been assessing progress in the trade facilitation policy environment since 2012 through the Trade Facilitation Indicators (TFIs) (Box 4.4), which provide a structured framework for delineating the border processes and trade facilitation measures underpinning CBAM implementation, and for benchmarking and improving these processes at country level.

Box 4.4. OECD Trade Facilitation Indicators (TFIs)

The TFIs are a set of evidence-based metrics developed by the OECD to assess how countries implement trade facilitation measures, in line with the WTO Trade Facilitation Agreement (TFA). Each indicator is scored from 0 (worst) to 2 (best), based on both regulations and their actual implementation. The TFIs provide a structured way to benchmark performance, identify gaps, and support policy reforms across 163 economies.

The four main policy areas covered are:

• Transparency and predictability (information availability, involvement of the trade community, advance rulings, appeal procedures, fees and charges);

• Automating and streamlining procedures (formalities related to documents, automation, and procedures);

• Border agency cooperation (internal and external);

• Governance and impartiality.

Source: OECD (2025[7]).

4.3.1. Trade facilitation tools relevant for CBAM implementation

The introduction of CBAM brings a new layer of complexity to customs processes, emphasising the relevance of a strong trade facilitation policy environment. As CBAM enforcement requires detailed verification and data transmission (Section 4.1), it directly affects workload at the border and can increase transaction costs and clearance times. If not carefully integrated into existing processes and systems, the additional documentation and verification requirements risk disrupting trade. A trade facilitation lens is therefore essential to maintaining procedural efficiency and minimising administrative burdens while ensuring compliance.

Information availability, automation and streamlining of procedures, and border agency cooperation are particularly relevant in the CBAM context. The following TFI areas appear most relevant for CBAM implementation:

• Transparency and predictability: TFI (A) Information availability (e.g., publication of customs and trade-related regulations, web portals);

• Automating and streamlining procedures: TFI (G) Automation (electronic data transmission, digital tools for customs clearance and risk management); TFI (H) Procedures (streamlined and simplified customs and border procedures);

• Border agency cooperation: TFI (I) Internal cooperation (institutional frameworks and systems for coordination between domestic agencies); TFI (J) External cooperation (coordination between border agencies of different countries).

4.3.2. Potential disruptions caused by CBAM for existing trade facilitation tools

The new procedural requirements introduced by CBAM can challenge the smooth functioning of existing trade facilitation tools. EU Member States have a range of tools in place such as pre-arrival processing, Authorised Operator (AO) programmes, Single Window systems, automated risk management, and border agency cooperation mechanisms. CBAM introduces new compliance requirements that may not yet be fully integrated into border procedures and information systems. Without adaptation, this misalignment could result in delays, duplication, or inefficiencies at the border.

The rollout of the CBAM can create risks of disruption to some particular trade facilitation elements. This includes information availability to facilitate trader compliance; automated and electronic clearance of import declarations; pre-arrival processing; risk management; Single Window systems; interconnected systems supporting border agency cooperation; post-clearance audits; and Authorised Operator programmes.

A lack of clear, comprehensive, and accessible information may complicate importers' ability to comply with CBAM obligations. Under the CBAM, importers need clear guidance on their obligations, procedures, and how to access systems such as the CBAM Registry. Missing, inconsistent, or inaccessible information can create uncertainty across CBAM goods supply chains and increase the risk of non-compliance.

CBAM procedures could place specific pressure on automated customs clearance and audit. Trade facilitation aims to speed up customs processes through automation, but the CBAM introduces additional checks – verifying CBAM status of goods and confirming declarant authorisation – which could affect automation, pre-arrival processing, and audits, increasing administrative burden and importation times.

Limited integration and interoperability of CBAM data with existing systems and digital platforms could cause fragmentation. Tools such as electronic data transmission or digital Single Windows are designed to streamline trade by consolidating procedures across border agencies. If CBAM requirements and data (such as the CBAM Account Number or declarant authorisation status) are handled separately, the result can be fragmented or duplicative processes, manual handling, and delays.

New risks and criteria for CBAM compliance could disrupt customs risk management systems and AO programmes. The CBAM brings new types of risks, such as emissions misreporting or circumvention attempts, which may not be fully embedded in current risk systems and selectivity criteria. Without harmonised criteria, Customs Authorities may apply inconsistent controls, leading to duplication and delays. AO frameworks reward compliant traders with simplified procedures and faster clearance, but if CBAM processes are not integrated into AO programmes, operators may lose AO benefits (e.g., because they need to also be an authorised CBAM declarant), adding complexity for importers.

4.3.3. How can a trade facilitation lens help to integrate new CBAM tasks at the border?

Trade facilitation plays a critical role in integrating CBAM requirements at the border. CBAM creates new tasks for customs such as identifying whether imported goods fall under its scope and verifying the authorisation status of CBAM importers that must be carried out before or at the moment of release for free circulation. Done manually, these tasks risk slowing processes and fragmenting workflows. A strong trade facilitation policy environment can help customs embed CBAM tasks and checks into procedures and systems, for example through automated and electronic data transmission (Table 4.3).

Table 4.3. New CBAM tasks: how trade facilitation can help

Customs role in CBAM Regulation	New CBAM tasks for customs	Relevant TFIs	How trade facilitation can help
Enforce the regulation at the border and carry out related checks	Additional checks necessary to identify CBAM goods imports and to verify the authorisation status of CBAM importers during the customs import clearance	Automation (TFI G); Procedures (TFI H)	Automatic use of the CBAM Registry and TARIC codes for CBAM checks Integration of the identification of CBAM goods and the verification of the authorisation status of importers in customs clearance
Communicate relevant information (European Commission and NCA)	New data elements (e.g., CBAM Account Number) and technical interoperability with new databases (e.g., CBAM Registry) necessary	Automation (TFI G); Internal Cooperation (TFI I); External Cooperation (TFI J)	Automatic and electronic transfer of data to the European Commission (e.g., through EU surveillance system SURV3) Automatic and electronic transmission of new CBAM data elements with the NCA
Assist the European Commission (circumvention)	New information about CBAM obligations to importers necessary	Information Availability (TFI A); Procedures (TFI H)	Customs integrate clear, comprehensive and accessible information about CBAM obligations in their communications with importers
Inform importers	New CBAM circumvention risk criteria and analysis (e.g., artificial splitting of shipments) necessary	Automation (TFI G); Internal Cooperation (TFI I); External Cooperation (TFI J)	Customs use electronic risk management (CRMS2) and import control systems (ICS2) to support sharing risk alerts and risk analysis for CBAM circumvention investigations with the European Commission

Source: Authors.

CBAM checks should be fully integrated into customs clearance procedures and systems. To enforce the CBAM effectively, Customs Authorities need to identify CBAM-covered goods and verify the authorisation status of importers during clearance. This requires automatic use of TARIC codes and validation against the CBAM Registry, embedded into existing clearance procedures and supported by automation and updated operational processes.

Customs Authorities also play a role in ensuring automatic and electronic data transmission with the European Commission. As described above, Customs Authorities must capture both existing and new data elements in customs declarations and share this information with the Commission. In practice, this requires updates to national customs systems and full technical interoperability with SURV3 and the CBAM Registry, subject to forthcoming implementing acts.

Customs Authorities can support the European Commission with targeted risk analysis and alerts on CBAM circumvention. They should apply new risk criteria (e.g., shipment splitting) and use electronic systems such as CRMS2 and ICS2 to share alerts and intelligence with the Commission. This effort relies on automation and structured cooperation between national and EU levels.

Customs Authorities can also provide clear, accessible information to help importers comply with CBAM obligations. Importers need to understand their CBAM responsibilities including authorisation, data submission, and reporting; and customs should embed targeted, up-to-date guidance in their communication channels.

Customs Authorities have several trade facilitation tools at hand, which are relevant for the efficient CBAM implementation at the border (Recommendation 14).

Recommendation 14: Leverage trade facilitation measures for customs-related CBAM implementation

Indicative timeline: Short to medium term

Description: Building on and leveraging existing trade facilitation measures to integrate CBAM tasks includes:

• Transparent and predictable information on CBAM-related requirements: Enhance CBAM-related communication and support through dedicated information channels. Make use of national secure platforms. Align messaging, using clear and differentiated communication for importers and indirect customs declarants;

• Automated and streamlined procedures: For example, clarify the role of CBAM authorisation processes in AO programmes and so that operators processing significant volumes of CBAM goods can retain facilitation benefits while meeting CBAM obligations. Use digital platforms such and developments in the context of the EU Customs Reform;

• Internal co-operation: Expand collaboration with the NCA and other relevant agencies. Establish regular, structured coordination between the Customs Authorities, the NCA, other relevant ministries and agencies (e.g. ministry of energy, national accreditation bodies, local customs offices), and border agencies;

• External co-operation: Facilitate exchange of operational experiences and best practices between Customs Authorities and the European Commission, focusing on CBAM risk management, automation of border procedures, CBAM data interoperability, and monitoring the new de minimis exemptions.

References

[2] European Commission (2025), TARIC Consultation, https://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp?Lang=en.

[4] European Commission (2025), Taric Integration of the Carbon Border Adjustment Mechanism, https://circabc.europa.eu/ui/group/0e5f18c2-4b2f-42e9-aed4-dfe50ae1263b/library/87a9cf1e-7417-4b18-97c8-3e1430cdd958/details.

[5] European Commission (2025), The EU Single Window Environment for Customs, https://taxation-customs.ec.europa.eu/eu-single-window-environment-customs_en.

[3] European Commission (2024), CBAM - TARIC data - Explanations, https://circabc.europa.eu/ui/group/0e5f18c2-4b2f-42e9-aed4-dfe50ae1263b/library/87a9cf1e-7417-4b18-97c8-3e1430cdd958/details.

[1] Eurostat (2025), Gross value added and income by detailed industry (NACE Rev.2) [nama_10_a64], https://ec.europa.eu/eurostat/databrowser/product/page/nama_10_a64.

[7] OECD (2025), OECD Trade Facilitation Indicators: Monitoring Policies up to 2025, OECD Publishing, Paris, https://doi.org/10.1787/fd6f27dc-en.

[6] OECD (2025), “The digitalisation of trade documents and processes: Going paperless today, going paperless tomorrow”, OECD Trade Policy Papers, No. 297, OECD Publishing, Paris, https://doi.org/10.1787/64872f25-en.