26 September 2023

Position on the approach and roll out of the Carbon Border Adjustment Mechanism (CBAM): recommendation to revisit and postpone its requirements

As a reporting obligation for October 2023 stemming from the EU Carbon Border Adjustment Mechanism (CBAM) approaches, EEA and CLECAT would like to express their concerns on the challenges economic operators are currently facing.

In particular, the EEA and CLECAT would like to express serious concerns regarding the limited time allocated for economic operators to implement the required obligations in a successful and compliant manner, also in view of the restricted guidance material currently available, as well as concerns on the onerous liability imposed onto indirect customs representatives to be automatically representing non-EU established importers given the difficulty in obtaining data elements which are not easily accessible.

The attached joint EEA-CLECAT position paper further elaborates on the associations’ concerns and recommendations.