CBAM is no longer “reporting only”.

From 2026 onwards, importing in-scope goods can entail direct financial exposure, while expectations around governance and substantiation become more stringent. Even when starting with default values for embedded emissions, a controlled and traceable approach remains essential.

In practice, the key is to have the operating model in place before the goods reach the border:

• Scope & classification: confirm whether the goods flows fall within CBAM scope and determine the CN/TARIC classification used operationally.

• Roles & accountability: identify who acts as the Authorised CBAM Declarant (registry access, certificates, declaration) and embed this in internal governance.

• Exclusions / thresholds: assess possible exclusions and manage thresholds consistently (including the 50-tonne de minimis, where applicable) throughout the calendar year.

• Data & audit trail: ensure traceable quantities, supporting documents and a robust file structure—whether using actual emissions data or default values.

• Budgeting & contracts: CBAM becomes a budget line. Cost forecasting and contractual allocation (supplier/customer) must be addressed upfront.

Customs is not where CBAM starts: it is the first formal checkpoint. If upstream fundamentals are not in place, CBAM risk typically materialises as delays, corrections and unexpected cost.

How DTB supports importers
DTB translates the regulation into a workable import process: scope screening, governance around exclusions/de minimis, CERTEX alignment and audit-ready dossier building—so import flows remain compliant and financially predictable.

Want a CBAM readiness checklist tailored to your import flows? Get in touch with DTB.