The EU Carbon Border Adjustment Mechanism (CBAM)
The Danish Energy Agency is the competent authority for the EU’s Carbon Border Adjustment Mechanism (CBAM) in Denmark. The purpose of CBAM is to reduce carbon leakage and lower CO₂ emissions both within and outside the EU.
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.
If you have received a notification letter from the Danish Customs Agency, it means that your company imported CBAM-covered goods during the relevant quarter and you are therefore required to report emission values in the CBAM Registry. If you have not received a notification letter during a quarter, no reporting is required.
Before your company can access the CBAM Registry, your company’s MitID administrator must assign one or more employees the roles and rights to access the CBAM Registry on behalf of the company.
Assign roles and rights via TastSelv Erhverv
Find further guidance on roles and rights on the Customs Agencies website
Once these steps are completed, you can log in to the CBAM Registry
Goods subject to CBAM are listed in Annex I of the CBAM Regulation. A good is subject to CBAM if its intrinsic value per shipment exceeds EUR 150. This applies to both finished goods and products for further processing.
Read Annex I of the CBAM Regulation
If you have received a letter and believe that a particular good you have imported is not subject to CBAM, it may be due to incorrect information in your customs declaration. You can apply for a correction of your customs declaration via the Danish Customs Agency’s website.
Apply for an amendment to your customs declaration with the Customs Agency
Once you have applied for the correction, please send the receipt and confirmation to the Danish Energy Agency at CBAM@ens.dk. Your reporting obligation for the specific good(s) will then be suspended.
If you intend to use a consultant or advisor to submit your CBAM report, they must be granted access to the CBAM Registry as if they were an employee of your company.
The company’s MitID administrator assigns the representative the necessary access rights via TastSelv Erhverv.
Assign roles and rights via TastSelv Erhverv
Currently, it is not possible to use the Revisorordning, as the CBAM Registry does not support this type of access.
If you wish to use an indirect customs representative, their company must be listed with representation code 3 'indirect representation' on the customs declaration for CBAM-covered goods.
An indirect customs representative must access the CBAM Registry using their own EORI number. The representative submits the declaration in their own name on behalf of the importer. It is possible to act as an indirect customs representative during customs clearance, and still reject the CBAM responsibility. In such cases, the indirect customs representative must notify the importer that they reject the CBAM responsibility after which the importer remains responsible for the CBAM obligations. Various customs rules also apply for indirect representatives.
Contact the Customs Agency for more information regarding customs rules
If an importer, listed in the customs declaration, is established outside the EU, customs clearance must be performed by an indirect customs representative. This representative must also be listed with representation code 3 (indirect representation). In this case, the indirect customs representative agrees to assume all CBAM obligations that would otherwise rest with the EU-based importer.
An indirect customs representative accesses the CBAM Registry using their own EORI number and submits a single CBAM report, covering all importers whose CBAM responsibility they have assumed.
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.
The specific commodity code (HS/CN/TARIC) listed on the customs declaration determines whether the import is subject to CBAM. You can view the customs code on your customs declaration in the customs import system.
Request access to the customs import system
If you used a freight company, customs broker or similar, you can contact them to obtain your customs declarations.
From the third quarter of 2024 onwards, it is no longer possible to use default values in the CBAM Registry. You are required to use the actual emissions provided by your supplier or the manufacturer. If actual emissions data cannot be obtained, you must indicate in the CBAM report that all available options to obtain them have been attempted.
If the actual data are not available, you must specify the following in the CBAM report:
- Direct embedded emissions – Type of determination: 'Actual data not available'.
- Additional Information: Provide an explanation (in English) for why the actual data are not available.
- Supplementary: Attach documentation showing attempts to obtain actual data, e.g., correspondence with your supplier or the manufacturer.
If this approach is applied, the CBAM Registry will insert 0-values in the field for emissions data. The report will be considered incorrect/incomplete by the European Commission. You may still submit the report, but the Danish Energy Agency may follow up, on behalf of the Commission, regarding the availability of actual data.
The European Commission has prepared a user manual for the Transitional CBAM Registry, which outlines the functioning and step-by-step approach to prepare a quarterly report in the registry.
Access the user manual for declarants on The European Commission’s website
How to report electricity in the CBAM Registry
If you import electricity from third countries, you are also subject to CBAM reporting requirements.
The reporting obligation applies to the entity listed as the recipient on the customs declaration, unless an indirect customs representative is applied.
According to customs regulations, the party responsible for balancing (balance-responsible party) who brings electricity into free circulation is accountable for ensuring the electricity is properly declared with customs.
If the recipient of the electricity, i.e. the importer, is listed on the customs declaration with a non-EU address, the customs clearance must be conducted by an indirect customs representative.
Import data, including commodity code, quantity, country of origin and customs procedure code, can be found on your customs declaration. Please note that reporting must be based on the gross import of electricity, not the net import.
Emissions data must be reported in the CBAM Registry as part of the reporting process.
For imports of electricity, values must be reported based on default emission factors (tCO₂/MWh), applicable to the third country where the electricity was produced. When using the European Commission’s default values based on IEA data, the emission factor is filled in automatically.
To use actual emissions data for reporting imported electricity, the importer must fulfill the requirements set out in Annex IV, point 5 of the CBAM Regulation.
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.
If you encounter errors or challenges during reporting, please consult the error log for the CBAM Registry. The error log includes technical errors and errors due to discrepancies in completion of the CBAM report. If the error is not included in the log, do not hesitate to contact us at CBAM@ens.dk. Include a clear description of the error encountered and preferably a screenshot of the error.
Error log for the CBAM Registry
If you encounter technical challenges with your access to the CBAM Registry, you should contact the Danish Customs Agencies’ service desk at servicedesk@toldst.dk. You may first try deleting your browser history and cookies, or using an incognito browser.
The deadline for submitting reports in the CBAM Registry is the end of the month following the reporting quarter. If you miss the reporting deadline, you can request to reopen the report.
To reopen your report, go to 'My Quarterly Reports', select 'Request Delayed Submission' for the relevant quarter, and choose 'Requested by NCA'. The system will prompt you for a request ID. The request ID is: yourEORInumber-year-quarter.
If, after submitting your report, you wish to make changes, you can reopen the report by clicking ‘Amend’ at the top of the report view for the relevant report.
If the ‘Amend’ button is no longer available, please contact the Danish Energy Agency using the contact form below with the subject “Reopening of registered report”. In your message, provide the report ID and a brief explanation of why you wish to have the report reopened. Once the Danish Energy Agency has reopened the report, its status will change to ‘Under correction’, and you will have 30 days to make your changes before the report is closed again and the status is updated to ‘Registered’.
Frequently Asked Questions
The Danish Energy Agency does not have access to your customs data and therefore cannot inform you of which goods you have imported.
If you used a freight company, customs broker or similar, they may be able to provide your customs information.
You can also request access to the customs import system
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.