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ARTICLE · 22 OCTOBER 2025

CBAM Countdown Navigating Duties & Business Impact

Reporting obligations in force since October 2023; quarterly reports on imports, emissions, and CO₂ prices that are due in a third country​.

GermanyCorporate/Commercial Law

CBAM (Carbon Border Adjustment Mechanism) – what is it?

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EU mechanism to prevent carbon leakage by applying CO₂ pricing to imports of carbon-intensive goods, with the following timeline:

Transition phase incl. Omnibus simplifications (2023-2025)

  • Reporting obligations in force since October 2023; quarterly reports on imports, emissions, and CO₂ prices that are due in a third country.

  • Fines for non-compliance; de-minimis threshold exempts imports ≤50 tons/year.

Definitive period (starting January 2026)

  • Only approved CBAM declarants may import CBAM goods (if de-minimis rule is not applicable).

  • Annual declarations due by September 30, of the following year; independent third-party validation of declared values required.

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