CO2 Bepreisung und Nachweisdokumentation in für Deutschland relevanten Drittländern

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On 1 January 2026, the transition phase began for the CO2 border adjustment mechanism (in English: Carbon Border Adjustment Mechanism, abbreviated as CBAM), which the European Union had already introduced as a transitional phase on 1 October 2023. Under CBAM, it is an instrument of the European Union intended to ensure that imports of certain goods subject to CBAM obligations into the EU are subject to the same CO2 costs as the product manufactured in the EU. This is intended to prevent carbon leakage, i.e. the relocation by companies from the EU of their production to third countries where less stringent climate rules apply and costs can therefore be avoided. During the transition phase, approved CBAM declarants are subject to an annual reporting obligation, provided they import more than 50 tonnes of CBAM-relevant goods, electricity or hydrogen from third countries into the EU. The annual reporting obligation is linked to a duty to surrender CBAM certificates for each tonne of CO2 equivalent. If a CO2 price has been paid in a third country for the embedded (grey) emissions associated with the goods, the number of CBAM certificates to be surrendered may, in some circumstances,…

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