Background and Historical overview of CBAM

In summer 2021 the European Commission tabled the Fit for 55 climate package aimed at reducing greenhouse‑gas emissions by at least 55% by 2030 across the Union. A key component of the package is the introduction of the CBAM (Carbon Border Adjustment Mechanism), designed to remedy shortcomings of the EU Emissions Trading System (EU ETS) and mitigate competitive disadvantages faced by producers operating within Member States.

Essence of the CBAM regime

The CBAM transitional period, established to prevent circumvention of the EU ETS and carbon leakage (i.e. relocation of production to non‑EU countries), commenced across the EU on 1 October 2023, including in Hungary. The mechanism aims to assign a carbon price to imports into the EU whose production generates significant CO₂ emissions.

In its first phase, CBAM covers imports of carbon‑intensive goods and precursors such as cement, iron and steel, aluminium, fertilisers, electricity and hydrogen, which together representing over 50% of emissions in sectors covered by the EU ETS. As of 1 January 2026, CBAM has entered its second, definitive regime, introducing substantial changes and further expanding the compliance obligations for affected operators.

Administrative burden

Until the end of 2025, CBAM does not entail a payment obligation for importers and customs brokers, however, it does impose reporting requirements. The first reporting period covered Q3 2023, with submissions due by the end of January 2024. Failure to report or to report correctly may result in significant fines.

Given the scope of obligations, involving an experienced tax advisor can be highly beneficial. Preparing the report imposes a substantial administrative burden on importers, particularly when calculating embedded emissions for inputs and components, and in collecting information on any carbon price paid in third countries, which may reduce CBAM liability.

From 2026 onwards, a de minimis exemption of 50 tonnes per year narrows the group of CBAM-liable importers. Those exceeding this threshold must obtain CBAM declarant authorisation to ensure uninterrupted imports. Without this authorisation, customs authorities may refuse the release for free circulation of CBAM-covered goods and impose penalties.

CBAM advisory: services by Andersen

• Reviewing importers’ product flows (domestically produced vs. imported products)
• Identifying mis‑classified goods and revisiting tariff classifications
• Assessing importers’ existing customs compliance systems for CBAM‑specific requirements across the relevant product chains
• Supporting the acquisition of status of authorised CBAM declarant to ensure seamless importing