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European Union: The Commission publishes CBAM reporting requirements for transitional period

On 17 August 2023, the EU Commission adopted the implementing regulation regarding the reporting rules applicable during the transitional phase of the Carbon Border Adjustment Mechanism (CBAM). Our previous alerts on CBAM developments can be found here and here.

The CBAM formally entered into force on 17 May 2023. It requires importers to report the so-called ’embedded emissions’ of certain (mostly industrial) products and of electricity imported into the EU in order to ensure equivalent carbon pricing for imports and domestic (i.e., EU) products and electricity. A transitional phase will run from 1 October 2023 until 31 December 2025, during which only reporting obligations – but no carbon pricing – will apply. Carbon pricing will start applying as of 1 January 2026.

Source Baker & McKenzie

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