15 May 2024

CBAM: First Informal Expert Group Meeting

The inaugural meeting of the informal Expert Group on the Carbon Border Adjustment Mechanism (CBAM) took place online on April 23, 2024.  Hosted by the Directorate-General for Taxation and Customs Union (DG TAXUD), the meeting marked the beginning of a collaborative effort to guide the implementation of CBAM during its transitional phase and the definitive period, which is set to commence on January 1, 2026.  The expert group comprises representatives from EU Member States, industry associations, NGOs, civil society, observers from third countries and international organizations.

The session began with a welcome from DG TAXUD, acknowledging the participants’ commitment to refining CBAM.  Members adopted the agenda and procedural rules unanimously. This established a framework for regular interactions, including potential hybrid meetings in Brussels.

Adoption of Implementing and Delegated Acts – Possible Revision of CBAM

DG TAXUD outlined the group’s annual work plan.  It highlighted the European Commission’s plans to adopt implementing and delegated acts per the CBAM Regulation.  The European Commission expects to report to the European Parliament and the Council by the end of 2025.  A possible revision of the CBAM Regulation in 2025 could introduce both technical adjustments for 2026 and more extensive changes.

Key Upcoming CBAM Regulatory Actions

Key upcoming regulatory actions include implementing acts for the CBAM Registry and the authorization of CBAM declarants.  Member States will soon receive the proposals. Additionally, a delegated act regarding CBAM certificates, an implementing act on customs procedures, and various acts on accreditation and verification are expected by the end of 2024.

CBAM Analytical Workstreams and Milestones

DG TAXUD also introduced its analytical workstreams and milestones, covering potential extensions of CBAM to more downstream goods and transportation.  These also include the methodology for calculating embedded emissions, electricity CO2 emissions factors for third countries, indirect emissions, accreditation and verification processes, default values for post-2026, rules for free allocation adjustment, and adjustments due to third-country carbon pricing.

Reporting Default Values

DG TAXUD confirmed that default values published in December 2023 would be usable without limits until July 31, 2024.  For the fourth reporting period (Q3 2024), declarants must therefore report actual values, with submissions due by October 31, 2024.

First Insights on CBAM Reporting

Participants shared preliminary insights from the first reporting period (Q4 2023), noting over 15,300 reports submitted and 3,100 in draft status.  Serbia ranked among the top 25 reporting countries by the number of submitted reports.  The meeting evaluated this as a strong response, given the recent implementation of the CBAM Regulation.

The Declarants Authorization Process

The session concluded with a presentation on the CBAM declarants’ authorization process.  The session emphasizing the importance of timely applications in 2025 to ensure authorization by January 2026.  DG TAXUD also provided an overview of the CBAM Registry.  The meeting encouraged participants to contribute suggestions for future agendas, and no further comments.


Vasilije Bošković, Nikola Ivković