CBAM – The Carbon Border Adjustment Mechanism
How CBAM affects imports, when reporting is required, and how to handle CBAM document codes in EmmaSped
What importers need to be aware of The Carbon Border Adjustment Mechanism (CBAM) applies to certain goods imported into the EU and aims to ensure that imported products bear a similar carbon cost as goods produced within the EU.
1. Check whether your goods are covered by CBAM
CBAM applies to specific product groups such as:
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Iron and steel products (and articles made from them)
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Aluminium
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Fertilisers
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Cement
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Certain chemicals
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Electricity
Whether a product is covered is determined by its Combined Nomenclature (KN code). Always verify the KN code against the customs tariff.
2. Annual volume is crucial – the 50-tonne threshold
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Under 50 tonnes per year (CBAM goods):
You do not need to apply for approved CBAM declarant status.
👉 Use document code Y137 – Imports under the 50-tonne annual threshold. -
Over 50 tonnes per year (CBAM goods):
You must apply to become an approved CBAM declarant via the CBAM register.
👉 The declaration must refer to the correct CN code and the appropriate CBAM Y-code.
3. CBAM codes must currently be entered manually in EmmaSped
Until further notice, CBAM document codes (Y-codes) must be entered manually in EmmaSped.
Users must therefore:
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Identify whether the goods are CBAM-relevant
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Confirm the annual import volume
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Select and enter the correct Y-code themselves
4. Transitional period and future requirements
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1 October 2023 – 31 December 2025:
CBAM reporting is required via the EU CBAM transitional register. Importers are notified by Customs and must submit quarterly reports. -
From 1 January 2026:
CBAM becomes fully enforceable. Imports over 50 tonnes per year will not be released unless the importer has approved CBAM declarant status (or has applied before 31 March 2026 and declares the application number).
Applicable CBAM document codes from 1 January 2026
The following document codes apply to CBAM from 1 January 2026:
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Y128 – Registered CBAM declarant
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Y134 – Exemption for goods originating in Büsingen, Helgoland and Livigno
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Y135 – Goods for military purposes
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Y136 – Electricity or hydrogen within the EU Economic Zone (EEZ) or continental shelf
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Y137 – Imports below the annual threshold of 50 tonnes
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Y237 – Goods of EU origin (re-import)
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Y238 – Application submitted to become an approved CBAM declarant before 31 March 2026
Key takeaway
✔ Always verify the CN code
✔ Keep track of your total annual CBAM volume
✔ Under 50 tonnes → Y137
✔ Over 50 tonnes → apply for CBAM approval and use the correct Y-code
✔ CBAM codes must currently be entered manually in EmmaSped