Key Impact of EU’s Carbon Border Adjustment Mechanism

18 February 2026 7 min read

Climate change is a global problem that needs global solutions. As the EU raises its own climate ambition, and if less stringent climate policies prevail in many non-EU countries, there is a risk of so-called ‘carbon leakage’. Carbon leakage occurs when companies based in the EU, move carbon-intensive production abroad to countries where less stringent climate policies are in place than in the EU, or when EU products get replaced by more carbon-intensive imports. As such, there is a need to motivate greener ways of production across the globe.

What is the EU Carbon Border Adjustment Mechanism?

The Carbon Border Adjustment Mechanism (CBAM) is the European Union (EU)’s first-of-its-kind border adjustment mechanism for carbon dioxide (CO2) emissions, which aims to ensure that the cost of those emissions is adequately reflected in the price of certain products imported into the EU. This environmental policy tool targets products like cement, iron and steel, aluminium, fertilizers, electricity and hydrogen from non-EU countries, and is set to encourage cleaner industrial production.

Imported goods from all non-EU countries and territories into EU27 countries will be impacted by the CBAM.

The EU27 countries consists of Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.

The final phase of this regulation is effective 1st January 2026.

Date	CBAM deadlines
1 October 2023	Start of transition period
31 January 2024	Deadline to submit first CBAM Report (for Q4 2023)
1 January 2026	End of transition period, Go-Live of CBAM final phase
31 January 2026	Deadline to submit last CBAM Report (for Q4 2025)
1 February 2027	EU Member States start selling CBAM Certificates
30 September 2027	Deadline to submit first CBAM Declaration for 2026, along with corresponding certificates

CBAM applies to imports of certain goods, from all non-EU countries and territories into EU27 countries, whose production is carbon intensive and at most significant risk of carbon leakage. CBAM goods exceeding a total net mass of 50 tonnes per calendar year are in scope of this regulation.

The following exceptions apply:

Importers, including Authorized CBAM declarants, are exempt from CBAM obligations if, within a given calendar year, the total net mass* of their imported goods does not exceed the threshold (“single mass-based threshold”), which is currently 50 tonnes. It applies to the combined net mass of all covered goods, across all country codes, per importer and per calendar year.
For goods to be moved or used in the context of military activities, CBAM does not apply.
Goods originating in the following countries & territories: Iceland, Liechtenstein, Norway and Switzerland, Büsingen, Heligoland, Livigno, Ceuta, Melilla.

* Net Mass refers to the weight of the goods without any packaging or additional materials. It is the actual weight of the product being imported.

Impact of CBAM on shippers and receivers

As of 1st January 2026, the CBAM system will work as follows:

Shippers (from Rest of World to EU)

Importers (in EU)

CBAM declarations require knowledge of the overseas production processes and related carbon emissions.

Therefore, DHL Express can only clear CBAM shipments where an importer or receiver is EU established.
- CBAM shipments for which an EU Established importer / receiver is not available, will not be cleared at import and may be returned to origin at customers’ expense.
Shippers should ensure that they provide CBAM specific details for their goods in scope of CBAM to importers.
Shippers should inform their importers about their CBAM obligations towards the European Authorities

_{* As a customs broker, DHL Express is not in a position to know these details or to assess the accuracy or completeness of information that may be provided.}

Only authorised CBAM declarants will be permitted to import CBAM goods into EU27 if the threshold is exceeded. Therefore, where an importer is expecting to exceed the threshold, they will be required to obtain authorisation to import CBAM goods.
Authorised CBAM declarants exceeding the threshold within a calendar year, will be required to purchase and surrender CBAM certificates and submit an annual CBAM declaration for the preceding calendar year, via the CBAM Registry.
Entities who are currently reporting in the transition phase, or any new importer of CBAM goods established in the EU, needs to apply for the authorised CBAM declarant status via the CBAM Portal UUM&DS if the conditions so require (see the threshold).
Authorised CBAM declarant is defined as the importer of CBAM goods or the indirect representative of the CBAM importer.
Should the importer of CBAM goods, have a change in status (i.e. exceeding the threshold), it is important for this information be provided to DHL Express by the importer, to comply with the regulations.

If customers are authorised for CBAM, it is essential that they provide their CBAM declarant authorisation number (CBAM Account Number) to DHL Express. This information is critical because:

If an importer exceeds the 50-tonne threshold and fails to provide their CBAM declarant authorisation number, DHL Express will not be able to complete the necessary customs declarations.
The customs declaration will be rejected by the local customs authority, leading to potential delays, additional costs, or even the return of the shipment at the customer’s expense.
Timely communication of the CBAM declarant authorisation number as well as any related changes to such number ensures compliance with regulations and facilitates a smooth customs process.
The local DHL customs team will save the CBAM declarant authorisation number on file, allowing it to be used for future customs clearance declarations without the need to provide it every time for each shipment

How DHL helps in this changing landscape

DHL Express plays a crucial role in facilitating compliance for its customers by reaching out to importers of CBAM goods to gather necessary information about their CBAM status. However, DHL Express will not assist with CBAM registration or reporting, which may require importers to seek additional support to navigate these new regulations.

Importer EU Established	CBAM Import Volume Per Year	Shipment Clearance Procedure	CBAM Responsibilities
Yes	Less than 50 Tonnes	CBAM declarant authorisation number not required, but EU EORI is required, for import declaration.	CBAM Declarant = importer. DHL assumes no CBAM responsibility.
Yes	More than 50 Tonnes	CBAM declarant authorisation number is required, as well as EU EORI, for import declaration.	CBAM Declarant = importer. DHL assumes no CBAM responsibility.
No	Less than 50 Tonnes	DHL Express will only clear CBAM shipments if there is an EU-established importer or receiver. *	Not applicable.
No	More than 50 Tonnes	DHL Express will only clear CBAM shipments if there is an EU-established importer or receiver. *	Not applicable.

* Shipments without an EU-established importer/receiver may be returned to origin at the customer's expense.

As the EU implements CBAM, DHL Express remains committed to supporting customers through this evolving regulatory landscape. We play an essential role in enabling seamless, compliant cross border trade by collecting necessary customer information, ensuring accurate customs declarations, and facilitating communication between shippers and receivers. By maintaining transparent processes and proactively guiding customers on their responsibilities, DHL Express helps businesses navigate the complexities of CBAM while continuing to deliver reliable, efficient international logistics solutions.