CBAM transition period – what to expect?

Between October 1, 2023, and December 31, 2025, both EU and non-EU businesses, alongside public authorities, will undergo a carefully planned change to ensure they meet all CBAM requirements by the end of the transition period.

During the transition period, importers of CBAM goods will only be required to report greenhouse gas emissions embedded in their imports (both direct and indirect ones).

The reporting comes without any financial obligations or adjustments. The monitoring and reporting guidelines for the transitional period are outlined in the Implementing Regulation (EU) 2023/1773. The verification of these emissions by an external third party remains voluntary and not required by the Commission at this stage. Moreover, the Implementing Regulation offers a degree of flexibility in the values used to calculate embedded emissions on imports throughout the transitional phase.

Up until the end of 2024, companies will have a spectrum of reporting options:

• Reporting based on the EU methodology

• Reporting based on an equivalent method, with three viable options.

• Reporting based on default values, available only until July 2024 (specifically for Q4 of 2023 and Q1&Q2 of 2024).

The next stage is January 1, 2025, when reporters will be obliged to follow only the EU reporting methodology.

The Commission will carefully assess the experience and information gathered during the CBAM transition period to further improve the mechanism and facilitate the reporting process. This is why it is important to start your CBAM engagement from the very beginning in order to be able to provide your input into the improvement of the reporting system in the future.