Advancing the Implementation of the EU Carbon Border Adjustment Mechanism

Technical Summary

Policy and economic context

The CBAM forms part of the EU’s climate policy framework under the European Green Deal and the Fit for 55 package (Section 1.1). These initiatives aim to reduce net greenhouse gas emissions by at least 55% by 2030, relative to 1990 levels, and to support the transition towards climate neutrality by 2050. Within this framework, the CBAM complements the strengthening of the EU Emissions Trading System (EU ETS) by addressing the risk of carbon leakage. Carbon leakage may arise when more stringent climate policies increase production costs in regulated jurisdictions, leading production and associated emissions to shift to economies with less stringent policies. This risk is particularly relevant for emissions-intensive and trade-exposed sectors, such as iron and steel, cement, aluminium, fertilisers, electricity and hydrogen. Differences in carbon pricing across countries remain large, with the EU and its Member States among the jurisdictions applying relatively high explicit carbon prices.

The CBAM seeks to align the carbon cost of selected imports with the cost faced by EU producers under the EU ETS to reduce the risk of carbon leakage. It requires importers to report the embedded emissions of covered goods and, from the definitive period, to purchase and surrender CBAM certificates. Carbon prices effectively paid in the country of origin can be deducted, and the use of verified actual emissions is allowed. These design features aim to reflect differences in production processes and existing climate policies abroad, while supporting consistency with the EU’s international commitments.

The mechanism is being implemented in two phases (Section 1.2). The transitional period, from October 2023 to the end of 2025, served as a learning and preparation period, focusing on reporting obligations and data collection, without financial payments. The definitive period started in 2026 and introduced financial obligations for authorised CBAM declarants. Importers are required to submit annual declarations, report embedded emissions, ensure third-party verification, and surrender CBAM certificates priced in line with EU ETS allowances. This phase also coincides with the gradual phase-out of EU ETS free allowances, creating a synchronised approach where EU domestic producers face lowering free allowances while importers face increasing CBAM financial adjustment.

The development of a multi-dimensional framework encompassing data quality and compliance could inform the status of and support effective implementation of CBAM (Recommendation 1). Relevant indicators could include the share of importers meeting reporting deadlines, the completeness and accuracy of emissions data, the use of actual values relative to default values, the number of authorised declarants, changes in import patterns and trends in the emissions intensity of covered goods. Building expertise on carbon accounting, trade exposure, compliance risks and sectoral impacts would inform policy discussions and anticipate future changes to the CBAM Regulation that could affect its implementation.

The effective implementation of the CBAM involves several actors (Section 1.4). The European Commission provides the regulatory framework, develops methodologies, manages the CBAM Registry and oversees consistent implementation across EU Member States. National Competent Authorities (NCAs) are responsible for authorising CBAM declarants, monitoring compliance and applying penalties where needed. EU Member States have designated a diverse range of institutions as their NCAs, reflecting differences in national administrative structures (European Commission, 2026[1]). In addition, Customs Authorities support implementation through border controls and data checks. Finally, CBAM declarants – comprising importers and indirect customs representatives – are responsible for collecting emissions data from suppliers, ensuring verification and meeting reporting and CBAM certificate obligations.

CBAM framework and key features

The CBAM currently covers emission-intensive and trade-exposed sectors at risk of carbon leakage (Section 2.1). It applies to imports of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen identified through specific customs codes. The focus on basic materials reflects a desire to target sectors covered by the EU ETS where emissions are significant and embedded emissions can be measured relatively accurately. Some downstream products closely linked to these sectors are already included to reduce circumvention risks, and the European Commission has proposed extending coverage further to downstream iron, steel and aluminium products. Certain imports remain exempt, including goods from countries linked to the EU ETS, military goods, specific waste and scrap products, and imports below the 50-tonne annual de minimis threshold.

The CBAM is intended to mirror the EU ETS by pricing embedded emissions in imported goods through CBAM certificates (Section 2.2). CBAM declarants must purchase and surrender CBAM certificates corresponding to the embedded emissions of their imports, with each certificate representing one tonne of CO₂e. Certificate prices are tied to EU ETS allowance prices, ensuring alignment between the two systems. The number of certificates required is adjusted to account for any free allowances granted to EU producers and for carbon prices effectively paid in third countries. As EU ETS free allocation is progressively phased out, the CBAM obligation will increase correspondingly, maintaining equivalent carbon pricing for domestic and imported goods.

Accounting for carbon prices effectively paid in third countries is a central component of the CBAM. CBAM declarants can reduce their CBAM liability if an effective carbon price has already been paid abroad. The adjustment is based on the effective carbon price actually borne throughout the production process. Implementation questions remain pending, including the treatment of compliance offsets, voluntary carbon market (VCM) credits, implicit carbon pricing and non-pricing instruments, or export carbon taxes. From 2027 onwards, the European Commission is expected to provide default carbon price values by product and jurisdiction to facilitate compliance.

The CBAM establishes a dedicated monitoring, reporting and verification (MRV) framework (Section 2.3). From 2026, only authorised CBAM declarants – importers or indirect customs representatives – can import covered goods and must submit annual declarations detailing imported quantities, embedded emissions, carbon prices effectively paid in third countries and CBAM certificates due. The CBAM’s MRV framework combines actual installation-level data with the possibility of using default values where information is unavailable. While actual data provide greater accuracy, default values are conceived to create an incentive to report verified emissions data.

The calculation of embedded emissions relies on information from third-country producers. The CBAM methodology is largely aligned with EU ETS accounting rules but differs by focusing on product-level rather than installation-level emissions. It includes emissions associated with relevant precursor materials and expresses emissions as tonnes of CO₂e per tonne of product. To facilitate reporting, the European Commission provides standard templates and digital tools allowing foreign installations to transmit emissions data directly to CBAM declarants or through the CBAM Registry.

Third-party verification plays a key role in ensuring the credibility of reported emissions. During the definitive period, actual emissions data and evidence of carbon prices effectively paid in third countries must be verified by EU-accredited verifiers. These verifiers conduct risk assessments, review monitoring systems and perform on-site inspections of production facilities if appropriate before issuing verification reports. Verification is not required when declarants use default values to simplify compliance requirements.

Robust data management and enforcement systems are essential for the effectiveness of the CBAM (Section 2.4). The mechanism depends on accurate customs information, reliable emissions reporting and effective data exchange between Customs Authorities, NCAs and the European Commission. The European Commission cross-checks customs declarations against CBAM reports, while accredited verifiers assess emissions data. Ensuring consistent oversight across EU Member States is important to avoid divergent implementation practices.

Role of National Competent Authorities (NCAs)

NCAs plays a central role in implementing CBAM at the national level. Alongside the European Commission, it is the operational backbone of CBAM. From authorisation and revocation of the authorised CBAM declarant status, the review of CBAM declarations to the enforcement and data coordination, NCAs ensures that CBAM is implemented effectively in the national context.

Authorisation of CBAM declarants and registration of verifiers

NCAs responsibilities include authorising importers as CBAM declarants and registering accredited verifiers who are essential to the CBAM compliance process (Section 3.1). From 2026, only authorised CBAM declarants may import CBAM goods above the 50-tonne annual de minimis threshold. To become authorised, CBAM declarants must submit detailed applications which NCAs must assess based on criteria such as financial stability, legal reliability, and technical capability. For applicants not established in the two years preceding their application, NCAs must require and continually assess a financial guarantee to cover potential liabilities.

At the same time, NCAs must oversee the registration of accredited verifiers. NCAs are responsible for registering, updating and deregistering accredited verifiers in the CBAM Registry, ensuring only entities meeting specific requirements can act as CBAM verifiers validating embedded emissions and carbon pricing data, thus contributing to the overall integrity and reliability of CBAM.

Developing robust and efficient authorisation systems could support effective CBAM implementation. This includes establishing clear assessment frameworks for applications, periodically reviewing documentation requirements, leveraging automation or delegation of tasks where feasible (Recommendation 3), developing procedures and tools for determining and monitoring guarantees (Recommendation 4), facilitating the authorisation of electricity importers through coordination with relevant authorities (Recommendation 2), and implementing clear procedures for the registration and oversight of accredited verifiers. These measures can help ensure consistent decision-making, reduce administrative burdens and strengthen the integrity of the CBAM compliance framework.

Revocation of authorisations

NCAs must revoke authorisations when declarants require it, no longer meet CBAM requirements or commit serious non-compliance (Section 3.2). Declarants may request the revocation, notably if they no longer import CBAM goods. Revocations may also result from NCAs’ reassessments of the declarant’s status, including changes in compliance behaviour or eligibility. NCAs may initiate revocation proceedings, particularly if there is evidence of non-compliance. For serious breaches, immediate revocation may be necessary.

Revocation does not eliminate outstanding CBAM obligations. Even after losing their authorisation, former CBAM declarants remain responsible for submitting final CBAM declarations and surrendering any outstanding CBAM certificates. Where necessary, NCAs may prepare declarations themselves using available information and default values to ensure liabilities are settled.

Effective revocation procedures require proactive monitoring and clear operational processes (Recommendation 5). This includes the implementation of risk-based reassessment systems, the definition of clear revocation triggers, the establishment of procedures for managing appeals and post-revocation obligations, and the development of tools to support the preparation of substitute CBAM declarations where former declarants fail to comply.

Review of CBAM declarations

Reviewing CBAM declarations is a core enforcement function that ensures the accuracy of reported emissions and certificate obligations (Section 3.3). While the European Commission provides EU-wide oversight and risk analysis, NCAs are responsible for conducting detailed reviews of CBAM declarations containing information on the quantity of imported goods, embedded emissions, and the number of certificates surrendered, checking the accuracy and completeness of this data, identifying irregularities, ensuring consistency with verification reports and requesting corrections or additional document and determining corrective actions where necessary.

Targeted and risk-based reviews can help NCAs focus resources on the highest-risk cases (Recommendation 6). Developing review plans and risk profiles, strengthening staff expertise in CBAM emissions accounting and verification, establishing analytical tools for reviewing declarations and calculating CBAM certificate obligations, and leveraging information received from Customs Authorities, verifiers and the European Commission would facilitate the detection of irregularities and support consistent enforcement outcomes.

CBAM certificate management

CBAM certificates are the central compliance instrument of the mechanism and require ongoing monitoring and oversight by NCAs (Section 3.4). CBAM certificates must be purchased and surrendered by authorised CBAM declarants in accordance with embedded emissions and carbon prices effectively paid abroad as reported in CBAM declarations. Declarants are also required to hold enough certificates and surrender them annually. NCAs oversee compliance with annual surrender obligations and quarterly holding requirements and play a key role in addressing deficiencies identified by the European Commission.

Effective CBAM certificate management requires strong NCAs’ monitoring and operational capabilities (Recommendation 7). Dedicated CBAM certificate-tracking tools, clear operational procedures and close coordination with authorities involved in EU ETS implementation can help improve oversight of quarterly and annual CBAM obligations, facilitate the identification of emerging compliance risks and support the smooth functioning of the CBAM certificate system.

Penalties for non-compliance

NCAs are responsible for requesting correction and ultimately for imposing penalties when CBAM declarants fail to comply with their obligations (Section 3.5). Non-compliance may include not submitting CBAM declarations, not surrendering enough CBAM certificates, or submitting false information. Penalties are designed to reflect the seriousness of the offence and are based on the volume of undeclared emissions. While the exact enforcement mechanisms may vary across EU Member States, penalties must be effective, proportionate, and dissuasive, mirroring the EU ETS enforcement.

A transparent and predictable NCA enforcement framework can support compliance and legal certainty (Recommendation 8). The development of methodologies for calculating penalties and outstanding CBAM certificate obligations, together with clearly documented procedures for enforcement, appeals and recovery, can help ensure consistent treatment of non-compliance cases and strengthen the credibility of the CBAM framework.

Data exchange and communication

Effective data exchange and communication are crucial to NCAs’ operations (Section 3.6). NCAs must ensure the timely flow of information between themselves, Customs Authorities and the European Commission. Coordination with Customs Authorities is especially important to validate import data and ensure that only authorised CBAM declarants are importing CBAM goods. Since national customs systems generally cover only imports cleared domestically, interoperability with EU-level platforms, including the CBAM Registry, is essential to provide cross-border visibility and monitor each importer’s cumulative net mass of CBAM goods against the annual threshold. Clear communication with stakeholders is necessary to support compliance and transparency.

Effective communication and data-governance arrangements can advance CBAM implementation (Recommendation 9). Detailed operational guidance, staff training, contingency procedures, cooperation mechanisms with Customs Authorities and other NCAs, and robust data-protection measures can help improve the reliability, security and consistency of CBAM-related information exchanges.

Role of Customs Authorities

Customs Authorities are responsible for enforcing CBAM requirements at the border and play a central role in connecting customs procedures with the broader CBAM compliance framework. Through border controls, data collection and transmission, cooperation with NCAs and the European Commission, and engagement with importers and CBAM declarants, they contribute to the effective implementation, monitoring and enforcement of the mechanism.

Customs procedures and information systems

Customs Authorities enforce compliance at the border and provide critical import data to NCAs and the European Commission (Section 4.1). They are responsible for ensuring that only authorised CBAM declarants import CBAM goods, performing CBAM-related customs checks, transmitting relevant data through customs surveillance systems, supporting circumvention investigations, and informing importers of their CBAM obligations.

Effective implementation requires close coordination between Customs Authorities, NCAs and the European Commission, supported by adequate institutional capacity, IT systems and governance arrangements. Strengthening customs operational capacity, inter-agency cooperation and technological readiness can help ensure consistent implementation of CBAM requirements while minimising administrative burdens. Mapping operational gaps, clarifying responsibilities, enhancing IT interoperability and providing targeted guidance and training can support a smoother integration of CBAM tasks into existing customs procedures.

Enforcing CBAM at the border and carrying out related checks

CBAM enforcement at the border relies on a structured sequence of customs checks and the use of specific data elements and IT systems (Section 4.2). Customs Authorities must determine whether imported goods fall within the CBAM scope, assess whether CBAM applies based on customs procedures and exemptions, and verify that the importer holds the status of authorised CBAM declarant. Particular attention is required for exemptions, special customs procedures, electricity imports and the de minimis threshold.

Customs Authorities also play a key role in collecting and transmitting CBAM-related information. Most relevant data are already available through customs declarations, including CN codes, country of origin, quantities and customs procedures. However, CBAM introduces additional elements, such as the CBAM Account Number and authorisation status of declarants. In that context, strengthening Customs Authorities’ operational readiness would ensure that customs processes, IT systems and staff capacity are fully aligned with EU requirements (Recommendation 10). In addition, automatic transmission of this information is essential for monitoring and enforcement. Developing detailed operational guidance for customs checks and leveraging automated data transmission tools can help improve consistency, reduce administrative costs and facilitate compliance (Recommendation 11). In addition, embedding CBAM-related checks and data requirements within existing customs procedures and digital systems can support efficient border management while ensuring effective enforcement (Recommendation 12).

Customs Authorities also contribute to identifying and preventing circumvention. They support the European Commission by detecting anomalies in trade flows, investigating suspicious transactions and integrating CBAM risks into customs risk management systems. Information from customs controls and EU-wide databases can help identify practices such as shipment splitting, misclassification of goods or concealment of origin. Strengthening customs risk-management capabilities and integrating CBAM-specific risk indicators into existing customs control frameworks can support the early detection of circumvention attempts and promote a more coordinated enforcement approach across EU Member States (Recommendation 13).

Trade facilitation perspective

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). New procedures and limited integration of CBAM data may result in fragmented and manual processes and could disrupt automated customs clearance, leading to longer processing times. Moreover, new CBAM-related obligations and circumvention risks may impact customs risk management systems and other existing trade facilitation measures such as Authorised Operator (AO) programmes. Finally, inconsistent or incomplete information about the application of CBAM can lead to confusion and delays among traders. Building on and leveraging existing trade facilitation measures can help to integrate CBAM customs-related tasks (Recommendation 14).

At the same time, a trade facilitation perspective highlights opportunities to efficiently integrate CBAM-related procedures into overall customs and border procedures. Key areas for integration include automatic identification of CBAM-covered goods, verification of importer authorisation via EU Integrated Tariff (TARIC) document codes and the CBAM Registry, data exchange with the European Commission through interoperable IT systems such as the EU Surveillance system (SURV3), targeted risk management and common risk criteria for detecting circumvention, and the provision of clear, up-to-date guidance to support compliance.

Governance and stakeholder support and communication

Governance, stakeholder support and communication are critical enablers of effective CBAM implementation. Given the cross-cutting nature of CBAM, successful implementation depends on clear institutional arrangements, effective coordination across implementing authorities, constructive engagement with stakeholders, and accessible communication channels that support compliance and reduce administrative burdens.

Governance

A robust governance framework can strengthen coordination, accountability and the overall effectiveness of CBAM implementation (Section 5.1). The cross-cutting nature of CBAM requires cooperation across multiple national authorities, including the NCAs, Customs Authorities, EU ETS teams, ministries responsible for trade, industry and energy, national accreditation bodies (NABs) and transmission system operators (TSOs).

Clear governance arrangements can help clarify responsibilities, improve information sharing, facilitate decision-making and support adaptation to future regulatory developments. Establishing an governance roadmap, clear responsibility matrices and dedicated organisational structures can help improve institutional accountability and operational efficiency (Recommendation 15). Similarly, formal coordination mechanisms, such a permanent CBAM Interministerial Working Group chaired by the NCAs and involving key ministries and agencies, could support collaboration, strategic planning, policy alignment, operational efficiency, and rapid responses to emerging issues (Recommendation 16).

Engaging with relevant stakeholders can help identify challenges, clarify regulations, and co-develop workable solutions, while also improving transparency, trust, and compliance. The CBAM affects a wide range of stakeholders, including importers, service providers, industries, and academic experts, all of whom could offer valuable insights into its practical and legal dimensions. To institutionalise engagement with these actors, national authorities could explore the creation of national a CBAM Stakeholder Advisory Group, convening representatives from key sectors and organisations for regular consultations (Recommendation 17).

Stakeholder support and communication

Due to the extensive number of CBAM obligations, stakeholders require extensive support across various areas, including emissions reporting, methodology, IT access, and compliance (Section 5.2). To manage this demand efficiently, NCAs could establish a framework for categorising requests, setting tiered response time targets, and implementing a digital tracking system (Recommendation 18). Structured phone support and periodic performance reviews could further enhance responsiveness and stakeholder satisfaction. These improvements, supported by a dedicated response team, could help prevent delays and ensure smoother CBAM implementation.

Effective stakeholder support and communication are central to the success of CBAM implementation. NCAs already communicates with stakeholders through their websites, FAQs, email and phone support. These existing channels provide a foundation for a broader communication strategy. Given the complexity of CBAM obligations and the diverse groups involved, NCAs could implement a multi-channel communication strategy in co-ordination with Customs Authorities (Recommendation 19) and develop practical guidance tailored to national stakeholders (Recommendation 20). By combining robust request management, diversified communication tools, and accessible national guidance materials, NCAs could enhance compliance, reduce administrative burdens, and strengthen trust between themselves and stakeholders.

Table 1. List of recommendations on CBAM implementation

Topic	Recommendation	Indicative timeline	Brief description	Location in the report
CBAM policy developments	1. Develop metrics and expertise to assess impacts	Short term	Building expertise and developing CBAM-related metrics would help inform policy discussions and anticipate changes to the CBAM Regulation modalities that could affect its implementation	Section 1.3
Authorisation of CBAM declarants	2. Facilitate the authorisation process of electricity importers	Short term	Close coordination between NCAs and Customs Authorities, energy regulatory authorities and transmissions system operators is needed to in to identify and communicate with CBAM declarants importing electricity	Subsection 3.1.1
	3. Ensure that documents required from applicants are adequate and facilitate authorisation through automation or delegation	Short, medium and long terms	The list of documents required from applicants should be reviewed periodically to ensure that it remains adequate for assessing applications and identifying risk factors during the authorisation process, taking into account regulatory changes and operational experience. Automating or delegating part of the authorisation process to another public or private entity could facilitate CBAM implementation	Subsection 3.1.2
	4. Develop guidelines for communicating and tools for determining and monitoring guarantees	Short term	Operational capacity should be established to document and communicate guarantee requirements. This could include developing sample calculations for guarantee values and processes for periodic reassessment of guarantee based on new information (e.g., from customs declarations)	Subsection 3.1.3
Revocation of authorisations	5. Develop guidelines for the revocation procedure	Short term	Developing clear internal guidelines, capacity and responsibilities for revocation procedures and, where necessary, the establishment of CBAM declarations by NCAs can help ensure that only entities able to submit accurate CBAM declaration and surrender the correct number of CBAM certificates are authorised to import CBAM goods	Section 3.2
Review of CBAM declarations	6. Develop guidelines and capacity for reviewing CBAM declarations	Medium and long terms	Operational capacity should be established to review CBAM declarations and identify errors or non-compliance. This could include developing internal guidelines and building capacity needed to correct the number of CBAM certificates surrendered.	Section 3.3
CBAM certificates management	7. Develop a CBAM certificate management tool	Medium term	Keeping track of CBAM certificate obligations of CBAM declarants is vital to the integrity and functioning of CBAM. An automated digital tool to surveil relevant data for all CBAM declarants in real-time is therefore recommended	Section 3.4
CBAM penalties	8. Develop a penalty rulebook	Short and medium terms	Developing processes for detecting and addressing non-compliance, including setting penalty levels and thresholds, defining grounds for derogation, preparing penalty notification templates and establishing procedures for securing penalties would support effectively enforcing CBAM	Subsection 3.5.2
Data and information exchange	9. Develop instructions and capacity for the CBAM Registry	Short and medium term	Knowing and correctly using the functionalities of the CBAM Registry is essential to ensure data security and enable NCAs to fulfil their task. Building internal and stakeholder capacity to use the CBAM Registry is recommended, alongside developing IT-security guidelines and identifying alternative communication channels	Section 3.6
Customs procedures and information systems	10. Strengthen customs risk management to detect and prevent CBAM circumvention	Short and medium terms	Prioritising and adapting risk management systems to detect and prevent CBAM circumvention could address potential attempts to bypass the CBAM Regulation	Section 4.2
	11. Develop a step-by-step customs process for CBAM compliance checks	Short term	Developing detailed guidance on a step-by-step process would help to enforce CBAM at the border	Subsection 4.2.3
	12. Integrate electronic data exchange mechanisms and digital tools for CBAM tasks	Short term	Using automated and harmonised data exchange with the European Commission and NCAs can ensure efficient CBAM enforcement	Subsection 4.2.4
Customs Authority readiness	13. Strengthen Customs Authorities’ operational readiness for the definitive CBAM regime	Short term	Accelerating preparations to ensure that customs processes, IT systems, and staff capacity are fully aligned with EU requirements is necessary	Subsection 4.2.5
Trade facilitation tools in the CBAM context	14. Leverage trade facilitation measures for customs-related CBAM implementation	Short and medium terms	Building on and leveraging existing trade facilitation measures can help to integrate CBAM customs-related tasks	Subsection 4.3.3
CBAM governance, co-ordination across government agencies and stakeholder engagement	15. Establish a CBAM governance roadmap detailing responsibilities and legal basis for acting	Short term	Defining an internal governance roadmap mapping roles and responsibilities and providing the appropriate legal basis for conducting CBAM tasks would support an orderly and successful implementation of CBAM	Section 5.1
	16. Create a CBAM Interministerial Working Group (IWG) to support communication, information flow and co-ordination across different government agencies	Short term	Establishing a CBAM IWG, potentially in the form of an interministerial committee, as a permanent body, chaired by the NCA, can support efficient co-ordination across different government agencies and ameliorate the diffusion of information	Section 5.1
	17. Explore the creation of a CBAM Stakeholder Advisory Group	Medium term	Creating a CBAM Stakeholder Advisory Group would institutionalise stakeholder engagement and provide a structured way to gather feedback, test ideas, and build consensus, enhancing the quality and effectiveness of CBAM implementation	Section 5.1
Stakeholder support and communication	18. Strengthen the framework to ensure efficient processing of requests	Medium and long terms	Developing a structured processing framework of stakeholders’ requests can help to ensure timely and efficient responses and manage stakeholders’ expectations	Section 5.2
	19. Implement a multi-channel CBAM communication strategy	Medium term	Implementing a multi-channel communication strategy can enhance stakeholder engagement, by ensuring that all stakeholders can access information and support	Section 5.2
	20. Complement EU documentation with national guidance	Medium and long terms	Complementing EU-level documentation by developing domestic guidance could help to address specific and unanswered needs of national stakeholders	Section 5.2
Monitor progress in implementing recommendations	21. Monitor progress in implementing the recommendations	Short, medium and long terms	Establishing mechanisms for tracking the progress in the implementation of recommendations is essential to ensure they are fully and effectively carried out	Part 6.

Note: The indicative timeline depends on national priorities, NCAs’ and Customs Authorities’ capacity and CBAM policy developments at EU level.

Source: Authors.

References

[1] European Commission (2026), List of National Competent Authorities for CBAM, https://taxation-customs.ec.europa.eu/document/download/5595ce5b-9fd2-42f6-9908-ed6325338ffa_en?filename=20260626%20Updated-list-of-NCAs-for-CBAM.pdf.