The European Union has published new Implementing Regulation rules that set out how importers must prepare for the Carbon Border Adjustment Mechanism during its transitional phase. The measure, released in the EU’s official journal, clarifies procedures that will apply as the CBAM begins on October 1 and runs until the end of 2025. For companies trading covered goods into the EU, the publication shifts compliance planning from general expectations to concrete reporting obligations tied to carbon pricing and emissions data.
CBAM is designed to address competitive imbalances between EU producers that face carbon costs under EU climate policy and foreign producers that may not face comparable pricing. By discouraging reliance on lower-cost production routes that can involve higher emissions in jurisdictions with weaker environmental constraints, the mechanism is positioned within the EU’s broader drive toward carbon neutrality by 2050. While the transitional phase does not replace the underlying carbon pricing system, it establishes a reporting framework that will shape how trade flows are documented and assessed.
Transitional reporting starts October 1 and runs through 2025
The transitional phase begins on October 1 this year and continues until December 31, 2025. During this period, importers—or their indirect customs representatives—are required to take on significant responsibilities linked to CBAM quarterly reporting. The Implementing Regulation published today specifies what information must be compiled and submitted, making data governance a central operational requirement for affected businesses.
In practical terms, importers must be ready to support reporting that goes beyond trade documentation traditionally used at the border. The rules also reinforce that compliance is not limited to emissions accounting in isolation; it includes how emissions relate to carbon pricing outcomes reflected in the CBAM methodology.
What importers must report: quantities, emissions and carbon price
Under the transitional-phase requirements, importers are expected to provide a transparent account of the quantity of imported goods entering the EU market. The obligation covers both the total volume and the number of goods brought into the EU, ensuring that reporting can be linked to specific shipments and product coverage.
Importers must also report direct and indirect emissions associated with production of the imported goods. Direct emissions relate to emissions resulting from production itself, while indirect emissions cover emissions linked to associated processes or activities connected to that production chain.
Beyond emissions volumes, importers must indicate any carbon price due arising from those emissions. This requirement is intended to ensure that goods are treated as bearing a carbon price regardless of origin, aligning trade documentation with the mechanism’s climate-policy objective.
CO2 measurement methodology for quarterly submissions
The Implementing Regulation formally published today details the methodology for measuring, calculating and monitoring CO2 emissions. It is described as a key component of the CBAM quarterly reporting process required during the transitional phase.
The rules apply to all importers of products in six industries: cement, steel, aluminium, fertilisers, electricity, and hydrogen. For companies operating across these value chains—whether importing into the EU or sourcing from non-EU suppliers—the methodology will influence how emission factors are determined and how calculation approaches are documented for auditability.
Implications for EU ETS-linked industry compliance
Although CBAM is framed as a border adjustment tool rather than an extension of EU ETS allowances within the transitional period, its reporting requirements intersect with how industrial firms already manage carbon data under EU climate regulation. For EU producers operating under EU ETS disciplines, CBAM’s approach reinforces expectations around consistent emissions measurement practices when competing against imports.
For exporters outside the EU supplying covered sectors into Europe, the new rules increase pressure to provide structured information that can feed importer reporting obligations. Over time, this can affect procurement contracts and supplier engagement strategies as trading partners adjust to documentation standards tied to CO2 measurement and carbon pricing calculations.
Overall, today’s publication marks a concrete step in implementing CBAM as part of the EU’s wider Green Deal trajectory toward carbon neutrality by 2050. As companies move into the October 1 start date for transitional-phase quarterly reporting through end-2025, compliance readiness—especially around quantities, direct and indirect emissions data, and carbon price due calculations—will become a defining factor for importers across cement, steel, aluminium, fertilisers, electricity and hydrogen supply chains.