If you import goods into the EU, it’s your responsibility to establish whether they’re subject to the EU Carbon Border Adjustment Mechanism (EU CBAM).
Otherwise you could face fines for missing the reporting deadline on 31st January 2024.
At CarbonChain, we help manufacturers and traders navigate and automate their CBAM reporting. This quick guide helps companies solve the first challenge: identifying which goods fall under CBAM and what their CN codes are.
If you know the CN codes of your goods, it's easy to identify whether they're included in the EU CBAM. All products are listed in Annex I of the EU CBAM implementing regulation.
Don’t know your CN codes? Read on.
CN codes are related to TARIC and HS classifications. The EU CBAM implementing regulation refers to HS headings as well as CN codes, and you can work out your product's CN code if you know its TARIC code.
For any given product, the first few digits of its HS, CN and TARIC codes are the same, as follows:
In summary:
It's also worth being aware of the Harmonized Tarriff System (HTS): a 10-digit classification system used in the US to help determine customs duties to be paid on imports. HTS codes are 10 digits long, and the first 6 digits are the HS code that align to the EU’s classification system.
For more information on these codes, please consult the following resources: CN, HS, TARIC, HTS.
EU CBAM goods are identified by their CN code.
However, in EU CBAM implementing regulation, certain products (e.g. unwrought aluminium, code 7601) are listed by their 4-digit HS heading, rather than their 8-digit CN code.
If you operate an installation that may be producing CBAM goods, talk with your compliance and legal department. They will likely have been involved in determining and declaring the CN code of the products manufactured at your facility.
If you import goods that may be subject to CBAM, consult with your customs, procurement or logistics department. They will have information on the CN codes that sit within your import declarations (box 33 of an EU customs declaration).
Some products don't have a CBAM-covered CN code, but contain other products that do. We often get asked whether CBAM applies in this case.
The answer is no. The EU CBAM is only concerned with the final CN code of the good imported into the EU — and these are primarily ‘simple goods’.
In the case of car manufacturers:
What matters is what the CN code of the good is at the moment it crosses the border. It is irrelevant under CBAM if you are importing a good whose CN code is not listed, even if it’s made from a good whose CN code is listed.
If you’ve established that you import CBAM-covered goods, then start creating your first declaration to meet the 31st January 2024 deadline.
If you’ve established that you produce CBAM goods, then prepare for your customers to start requesting your emissions data. They will not be able to continue sourcing your products if you don’t provide this data.
Need help measuring emissions in compliance with CBAM?
Please note: some of these codes are 4-digit HS headings (the first 4 digits of CN codes that are covered by CBAM). View further guidance.
Please note: some of these codes are 4-digit HS headings (the first 4 digits of CN codes that are covered by CBAM). View further guidance.
Please note: some of these codes are 4-digit HS headings (the first 4 digits of CN codes that are covered by CBAM). View further guidance.