Customer Advisory: Carbon Border Adjustment Mechanism (CBAM)

The Regulation (EU) 2023/956 (CBAM Regulation) will apply in full from January 1, 2026. This means that goods covered by the CBAM Regulation (e.g., cement, fertilizers, iron, steel, aluminum, and goods made from these materials) can only be declared and released for free circulation if you, as the declarant, are an authorized CBAM declarant.

In order to avoid delays in the release of goods covered by the CBAM Regulation for free circulation when the CBAM Regulation comes into full effect on January 1, 2026, you must be approved as a CBAM declarant.

German customs therefore advises affected companies to promptly submit an application for approval as a CBAM declarant via the CBAM register to the competent authority. In Germany, the competent authority is the “German Emissions Trading Authority (DEHSt) at the Federal Environment Agency.”

Affected raw materials and products:

• Iron and steel (including intermediate and by-products)
• Cement
• Aluminium
• Fertilizers
• Electricity (electricity imports)
• Hydrogen

Detailed information on the approval procedure as a “CBAM declarant” is available on the website of the German Emissions Trading Authority (DEHSt) (DE only) and the European Commission.

As a Swiss company, please note that CBAM applies to imports into the EU and not the location of your business. The origin of the goods is the decisive factor. Under customs law, the importer must comply with this new EU regulation.

The so-called Omnibus Package I, which simplifies the CBAM Regulation, was published as Regulation (EU) 2025/2083 in the Official Journal L 310 on October 14, 2025, and entered into force on October 17, 2025. The German Emissions Trading Authority (DEHSt) has provided information on the most important changes and published guidance on registration for the regulatory phase starting January 1, 2026.

DSV in Germany will not apply for registration as a CBAM registrant and therefore cannot handle registrations on your behalf.

For further information, please reach out to your usual contact person at DSV.