Important Update: CBAM deadline on March 31, 2026

As of Jan. 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) is officially effective and the system is in the transition phase. This brings important new obligations and strict deadlines for importers of CBAM goods.

What you need to know

The date March 31, 2026 is a crucial deadline. Importers expecting to exceed the 50-tonne CBAM goods threshold in 2026 are required to register as an approved CBAM declarant by this date.

• Timely registration: If you submit your application before March 31, you may continue your import business while the application is pending.
• Consequences of late registration: After March 31, imports without formal authorization are no longer allowed. This could lead to delays at the border or unexpected fines.
• Lead time: Please note that the authorization process can take up to 120 days.

Document codes (Y codes)

To avoid customs delays, it is essential to use the correct document codes beginning in January 2026. Some important codes are:

• Y128: For authorized CBAM endorsers.

• Y238: For importers whose application was submitted before March 31 and is still pending.

• Y137: For imports below the threshold of 50 tons.

Take action

We advise you to proactively assess your import volumes and submit your application to the competent authority in the member state where you are located in a timely manner. For Dutch companies, this is through the Dutch Emissions Authority (NEa).

Download the full update for a detailed list of required actions and relevant document codes:

• Dutch
• English
• NCA for CBAM