What is CBAM and who is covered?
CBAM stands for 'Carbon Border Adjustment Mechanism'. The CBAM Regulation was introduced by the EU and governs the import of certain goods with high carbon emissions that are produced outside the EU.
From 2026, goods covered by CBAM may only be imported into an EU country by an authorised CBAM declarant. Your company is subject to CBAM if it imports goods from a country outside the EU customs territory, within one of the following product categories, and with a value exceeding EUR 150:
- Iron and steel
- Aluminium
- Cement
- Fertilisers
- Chemicals (Hydrogen)
- Electricity
Further information and guidance materials can be found on the European Commission’s website
If you do not find answers to your questions in the guidance below, you can contact the Danish Energy Agency using the contact form below. We are pleased to assist with specific issues encountered during reporting. Please note that, as a public authority, we are not allowed to provide counselling services, but can inform on reporting rules and provide assistance with technical issues.
CBAM simplification
The European Commission is currently preparing a CBAM simplification package, which includes proposed amendments to the CBAM Regulation regarding the definitive period.
These amendments are expected to introduce a threshold of 50 tonnes for the import of goods listed in Annex I of the Regulation.
Companies importing less than 50 tonnes of the goods listed above may therefore be exempted from the requirements in the CBAM Regulation as of 1 January 2026.
What does this mean for your reporting obligations?
All companies, importing CBAM-regulated goods from outside the EU, are formally required to report greenhouse gas emissions embedded in the goods they import. This remains valid until any changes to the Regulation enter into force.
For companies expecting to import less than 50 tonnes, the Danish Energy Agency recommends treating the transitional period through 2025 as a learning year, during which you may practice reporting without concern for future obligations. The Danish Energy Agency does not enforce or apply any penalties for missing or incomplete quarterly reports from companies that have imported, or will import, less than 50 tonnes of CBAM-goods in 2024 or 2025.
Companies importing 50 tonnes or more must continue reporting as usual.
Read more about the proposed amendments and follow the latest developments on the The Directional-General for Taxation and Customs Union (DG TAXUD)'s website
What to Do If Your Company Is Within Scope
CBAM is administered across the Danish Energy Agency, the Danish Customs Agency and the Danish Business Authority, so companies must familiarise themselves with the relevant rules from each authority.
How to report in the CBAM Registry
In the CBAM Registry, you complete a CBAM report by entering, among other things, the country of origin of the imported goods and the amount of embedded emissions in the goods.
How to report electricity in the CBAM Registry
If you import electricity from third countries, you are also subject to CBAM reporting requirements.
Errors encountered during reporting and reopening of reports
It is possible to reopen a submitted report, or correct errors during reporting. Reopening of a report is also referred to as an extension of the deadline.
Frequently Asked Questions
Contact
Did you not find an answer to your questions? You can use the contact form to contact us at the Danish Energy Agency. Please be as specific as possible in your inquiry.