The definitive phase of the Carbon Border Adjustment Mechanism (CBAM) begins in January 2026, and the European Commission has unveiled the draft Implementing Regulation outlining the criteria and procedures to obtain the status of an Authorized CBAM Declarant (1).
Starting from January 2026, all operators importing goods under the CBAM scope — such as cement, iron and steel, aluminum, fertilizers, electricity, hydrogen, and various downstream products — must qualify as Authorized CBAM Declarants.
Implications of Non-Compliance
This marks a significant milestone in the CBAM compliance journey. Non-compliance consequences will extend beyond current monetary penalties which, during the transitional phase, were considered to be only “a measure of last resort after communication from and with the national competent authority” (2). In fact, during the definitive phase, compliance with CBAM rules will be a prerequisite for business continuity. Operators that fail to secure the status of Authorized CBAM Declarant will be barred from importing CBAM-listed products into the EU.
How PwC Belgium Can Assist
To ensure compliance, we recommend that any company importing goods from outside the European Union undergo a CBAM screening of their customs declarations to identify necessary actions. At PwC Belgium, our team of carbon pricing, global trade and customs, and ESG experts is ready to assist you in navigating this regulatory landscape.
(3) https://www.pwc.be/en/services/tax-and-legal/CBAM.html
