CBAM reporting: portal live and background information

The EU portal for registration of CBAM goods is now live. Last week the Dutch Emissions Authority (NEa) in combination with the Dutch Customs Authorities broadcasted a webinar outlining the requirements for CBAM importers in the transitional phase which started in October 2023. In this article, you find the most relevant information from the webinar in relation to your CBAM reporting.

On the website of the Dutch Tax and Customs Authorities you also find some Q&A (in Dutch).

What does this mean for your organisation?

The webcast provided important and concrete information on the transitional period and reporting process. One of the key take-aways is that the transitional period should be utilized to learn so that you are fully ready and knowledgeable when the CBAM will impact your cost of doing business in 2026 and you need to purchase CBAM certificates.

Transitional period

The first two years of the CBAM legislation will be characterized by the learning process for those involved. Even though the importers of the goods in scope of CBAM might not yet have all required information available, a report needs to be filed every 3 months. It is important that the importers of CBAM goods include a national import code (in Dutch ‘Bescheidcode’) that indicates that the imported goods fall within the CBAM scope. The purpose of this code is for Dutch Customs to monitor whether the importers are aware of the fact that they import CBAM goods. If the importer lacks this code their import declaration will not be accepted (based on the HS code the authorities can easily filter the declarations).

CBAM importers are urged to hand in a report in time, even though some information may still be missing. The first two reports can be altered at a later date. Although the transition phase of the Carbon Border Adjustment Mechanism (CBAM) has only recently commenced, and penalties are only based on lack of effort put in the process and not on the output, it is crucial to acknowledge that initiating the collection process is essential as the requirements do increase over time. Therefore, it is highly recommended to establish effective communication with your suppliers as soon as possible.

CBAM portal

The European Commission has launched the electronic portal in which CBAM reporting will be done. CBAM reporters (established in the Netherlands) are able to gain access to this platform through the use of the digital identification system eHerkenning (level 3 minimum required). A user manual has also been published by the EC, which can be found here. For questions regarding access to the platform, reporters should address the Dutch Customs office, while questions regarding the reporting obligations should be addressed to the NEa.