The European Commission has issued detailed guidance on the integration of the Carbon Border Adjustment Mechanism (CBAM) into the EU’s TARIC customs system, setting the operational foundations for the mechanism’s full entry into force on January 1, 2026. The update introduces new certificates, revised import conditions and explanatory notes to ensure clarity for customs operators, while preparing EU systems for a shift from transitional reporting to full CBAM enforcement.
During the transitional period from October 1, 2023, to December 31, 2025, importers of CBAM goods have had to submit quarterly reports detailing embedded direct and indirect emissions, product quantities and carbon prices paid in the exporting country.
Until the end of 2025, measure type 775 appears in TARIC to indicate that imports fall under CBAM’s product scope. However, no certificates are required in this phase. Instead, footnote TM967 explains transitional reporting duties and clarifies temporary exemptions.
Mandatory certificate-based clearance for CBAM goods
From January 1, 2026, the system will change substantially. TARIC measure 775 will carry mandatory conditions that determine whether CBAM goods can legally be released into free circulation.
A set of certificates governs the admissibility of CBAM goods at customs. Certificate Y128 records the CBAM account number of the authorized declarant and is the basis for standard imports. Certificates Y134 and Y135 cover exemptions relating to special geographical territories or military-use goods, whereas Y136 verifies that electricity or hydrogen were produced in the continental shelf or exclusive economic zone of an EU member state. Certificate Y137 allows the 50-mt de minimis mass exemption to apply, while Y237 identifies goods produced in the EU and therefore excluded from CBAM obligations. Certificate Y238 is introduced for operators whose applications for CBAM declarant status are still under consideration, allowing importation until a decision is delivered. If none of these certificates apply, condition Y060 blocks the importation of CBAM goods.
Different rules for different CBAM product groups
Distinct operational rules for different CBAM product groups were also established. Cement, fertilizers, iron and steel, and aluminum are subject to both declarant-based and mass-threshold conditions, reflecting the new 50-mt annual de minimis exemption for each importer. Electricity and hydrogen are treated differently. These products cannot benefit from any mass-based exemption and are always fully subject to the CBAM requirements, meaning that only certificates related to authorized declarant status or other specific exemptions allow clearance.
New footnotes provide legal clarity and support enforcement
The updated TARIC introduces new explanatory footnotes to reinforce the customs architecture of CBAM.
Footnote CD01023 explains the conditions under which the de minimis mass exemption applies. Footnote CD01024 clarifies that CBAM does not apply to EU-origin goods, including processed goods re-imported under inward processing. Footnote CD01025 establishes temporary import arrangements for operators awaiting a decision on their declarant authorization application. In addition, TM967 is updated to clarify prohibited import situations and to reflect exemptions.