CBAM 2026 – Key Changes for Importers

As of 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM) will enter its definitive phase. This means expanded obligations for CBAM importers, including annual CO₂ emissions reporting and the requirement to purchase CBAM certificates.

1. Imports Only Through an Authorized CBAM Declarant (ACD)

From 2026 onwards, the import of goods covered by CBAM will be possible only through entities holding the status of an Authorized CBAM Declarant (ACD). This status can be obtained by submitting an application via the EU CBAM Portal.

The application may be submitted by:

• an importer established in the EU, or
• an indirect customs representative, provided they have the appropriate authorization.

In Poland, the competent authority will be the Director of the Revenue Administration Chamber in Poznań.

2. Annual CO₂ Emissions Declaration

Under CBAM regulations, importers will be required to report annually:

• the quantity of imported goods covered by CBAM,
• the CO₂ emissions associated with their production.

The declaration will become part of the broader documentation system linked to import settlements and environmental compliance monitoring.

3. Obligation to Purchase CBAM Certificates

Each importer will be required to purchase CBAM certificates corresponding to the level of CO₂ emissions attributed to the imported products.

In practice, this will represent an additional import cost, which should be taken into account when calculating the final price of goods—alongside elements such as import duties and VAT.

The purchase of CBAM certificates will therefore be one of the key obligations for CBAM importers starting in 2026.

The 50-Ton Threshold – Who Must Obtain ACD Status?

An importer does not need to obtain Authorized CBAM Declarant status if they import less than 50 net tons per year of CBAM-covered goods.

However, this exemption does not apply to imports of:

• electricity
• hydrogen

In these cases, CBAM obligations apply regardless of the imported quantity.

If a company expects to exceed the 50-ton threshold but has not yet obtained ACD status, imports may still be carried out provided that the application is submitted before the import takes place, but no later than 31 March 2026.

How to Access the CBAM Portal

Access to the CBAM system is provided through the PUESC platform.

Proper registration and configuration of user permissions are essential for:

• the efficient fulfilment of CBAM importer obligations,
• the correct handling of customs declarations.

Importers who already had access to the CBAM registry during the transitional phase will receive access automatically.

CBAM 2026 – Key Points at a Glance

Alongside CBAM 2026, the European Union is also implementing the EUDR (EU Deforestation Regulation), which introduces due diligence obligations for the import of selected goods.

EUDR will cover, among others:

• coffee
• cocoa
• timber
• soy
• rubber
• beef
• palm oil

How ATC Cargo Supports Importers in the Context of CBAM 2026

In light of the new regulations, we recommend:

• verifying whether imported goods fall under CBAM regulations,
• reviewing import procedures in line with the new requirements,
• consulting with a customs agency regarding reporting obligations and customs declarations.

ATC Cargo provides comprehensive customs services, including support as a customs agency in the implementation of CBAM 2026 and EUDR regulations. We assist companies in safely navigating the new CBAM importer obligations and adapting their import processes to current EU regulations.

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