TRANSITIONAL PERIOD VS PERMANENT SYSTEM & CBAM REPORTING OBLIGATIONS.
Are you confused regarding when exactly CBAM applies to your business?
Throughout the CBAM transitional period, which commenced on 1 October 2023 and concludes at the end of 2025, the reporting declarant, whether it be the importer or an indirect customs representative, is obligated to report quarterly the emissions embedded in CBAM goods without incurring financial adjustments. This interim phase allows for the seamless implementation of the permanent system.

Reporting declarants are advised to liaise with the national competent authority in their respective countries to gain access to the CBAM Transitional Registry. This platform serves as the designated channel for submitting quarterly CBAM reports.
The inaugural CBAM quarterly report, covering the reporting period from 1 October 2023 to 31 December 2023, was due by 31 January 2024, marking the initiation of compliance within the transitional framework.
CBAM REPORTING REGULATIONS
If you’re worried about CBAM and don’t understand what is needed in your reports, or even whether CBAM affects you, you aren’t alone. In this blog we will discuss this and answer all your potential questions.
Throughout the CBAM transitional period, spanning from 1 October 2023 to 31 December 2025, importers are required to submit quarterly CBAM reports. These reports must detail the goods imported in the preceding quarter and must be filed no later than one month following the quarter’s conclusion.
In accordance with Article 35 of the Regulation, the CBAM report should contain the following information:
- Total quantity of each type of CBAM good
- Actual total embedded emissions
- Total indirect emissions
- Carbon price owed in the country of origin for the embedded emissions in the imported goods, considering any applicable rebates or compensations.
This structured reporting ensures transparency and accountability in monitoring carbon emissions associated with imported goods during the CBAM transitional phase.