WE HAVE ANALYSED THE EU REGULATION ON THE CBAM REGISTER FOR YOU

WE HAVE ANALYSED THE EU REGULATION ON THE CBAM REGISTER FOR YOU

The European Union acted like clockwork. A year before the start of the CBAM target period, the Commission published a regulation describing the rules for the functioning of the CBAM registry. It is an ICT system that will enable the exchange of key information between importers and control authorities. This is where importers will submit their first annual CBAM declaration. The CBAM registry will be relevant from January 1, 2026, and will replace the transitional CBAM registry. The content of the regulation on the CBAM registry was announced on December 18, 2024.

 

ARE YOU CONFUSING THE CBAM REGISTER AND THE CBAM TRANSITIONAL REGISTER?

How does the CBAM registry differ from the transitional CBAM registry? The main differences are:

• The CBAM transitional registry was created for use during the CBAM transitional period, i.e., from October 1, 2023, to December 31, 2025. In reality, it will be usable until at least February 28, 2026, when the adjustment period for the fourth quarter of 2025 ends.
• The CBAM registry was created for use during the CBAM target period, i.e. from January 1, 2026. In reality, it will be available for use as soon as it is made available by the European Commission.
• The CBAM transitional register is used for submitting quarterly CBAM reports.
• The CBAM registry is used to submit annual CBAM declarations.

LOGIN VIA PROVEN SOLUTIONS

In order to log in to the CBAM registry, the EU's Single User Management and Digital Signature System (UUM&DS) will be used. In addition, Member States may incorporate a national user authentication system into the process of accessing the registry. In Poland, during the transition period, this role is performed by the Electronic Tax and Customs Services Platform (PUESC). It is likely that the same platform will be used for logging in during the CBAM target period. Businesses are hoping that proven solutions will streamline the user authentication process and navigation within the CBAM registry. When the first CBAM platform—the transitional registry—was launched, there were many technical problems.

 

OUTSOURCING OF SERVICES WILL STILL BE POSSIBLE

The importer will be able to grant access to their CBAM registry to a person acting on their behalf. That person will be able to perform the importer's CBAM obligations, such as annual reporting or obtaining emissions data from the database intended for producers. However, the Commission emphasizes that the importer is always responsible for fulfilling the obligations under the CBAM regulations.

 

DON'T IGNORE CBAM REGULATIONS

The importer's compliance with CBAM obligations will be verified through continuous monitoring and exchange of information between customs authorities, Member State authorities, and the European Commission.

The CBAM registry will contain, among other things:

• the option to apply for CBAM authorized declarant status, which must be obtained when importing CBAM goods into the EU
• annual declarations on the quantity of imported CBAM goods
• the option to apply for registration of operators,
• verification reports issued by CBAM verifiers
• information on CBAM certificates held by the authorized CBAM declarant

The European Commission will also use this register to analyze the risk of circumvention by importers. The control system is intended to be comprehensive and effective, so do not ignore the CBAM regulations.

If you need help fulfilling your obligations, please contact us. Our CBAM team has already helped dozens of importers identify CBAM goods, submit reports, and contact manufacturers.

 

LEGISLATION

Below is a link to the Official Journal of the European Union with the regulation in question:

Commission Implementing Regulation (EU) 2024/3210 of December 18, 2024.

 

ZAPRASZAMY DO KONTAKTU