The Tax Agency has issued an Information Note explaining how the Carbon Border Adjustment Mechanism (CBAM) on imports into the European Union will be applied in practice as of January 1, 2026.

From that date, when a company imports products subject to the CBAM, it must expressly indicate in the customs declaration whether it is authorized to import under this mechanism or whether it avails itself of any of the exemptions provided for. This will be done by means of a specific code included in the SAD.

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Obligations of the importing company

In the import declaration, the company must enter one of the CBAM codes defined by the regulations. The most common will be the one that identifies authorized importers, which requires a CBAM account.

There are, however, alternative codes for specific situations, such as small volume imports, certain special origins or transitional periods for companies that are still in the process of obtaining authorization.

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Adjustment periods or exemptions

The regulations provide for exemptions and transitional regimes, for example, for importers who do not yet have CBAM authorization, but have already applied for it, or for those who import small volumes. These options will be phased out over the course of 2026.

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Summary of most common CBAM codes

• Y128 – Authorized importer CBAM. General code. Used when the company already has a CBAM account. It is the only code whose number is automatically validated at EU level.
• Y238 – CBAM authorization requested, not yet granted. For importers who have applied for CBAM authorization prior to clearance, but have not yet received it. Applicable until 31/03/2026 (with transitional regime until September 2026).
• Y137 – Small volume imports. For unauthorized importers who import less than 50 tons per year of CBAM goods.
• Y135 / Y136 / Y237 – Specific exemptions. Applicable only in the specific cases provided for in the CBAM Regulation.
• Y134 – Excluded origins. For goods originating in Büsingen, Helgoland or Livigno.