CBAM: frequently asked questions and persistent misconceptions

Why CBAM already poses risks today

Since CBAM has become a structural part of customs controls, we see a clear evolution. Importers are more often confronted with delays, additional controls and discussions about responsibilities.

In many cases, costs or obligations only come to light when it is too late to adjust. This makes CBAM not only a compliance exercise, but also a risk that is best managed proactively.

In addition, CBAM touches several domains within your organization: from purchasing and logistics to finance and legal. Without clear coordination, a fragmented approach quickly emerges.

Risk: your goods are stopped at customs

A scenario we regularly see today: goods are temporarily blocked because the CN code is on the CBAM list, but the declaration contains insufficient information.

At that moment, customs cannot assess whether an exemption applies or not. The result is delay, additional questions and in some cases even blockage of the flow of goods.

So the key question is not only whether your product is subject to CBAM, but also whether you can demonstrate at the time of importation why it is or is not.

When are you potentially subject to CBAM?

At first glance, this seems like a simple yes/no question, but in practice there is more nuance behind it. It starts with a correct classification of your goods and a good view of your total imports.

• Are the CN codes used correctly coded and included in the CBAM list?

• Are goods in free circulation within the EU?

• Is the 50-ton threshold approached or exceeded and how stable are those volumes?

• Do they involve exceptions such as transit, temporary import or returning goods?

A correct assessment requires more than one data point and often requires a look at the entire calendar year as well as the organizational context.

The 50-tonne threshold: an underestimated tipping point

One of the most common misconceptions is that CBAM does not apply as long as you stay below 50 tons. In reality, we see that:

• volumes are considered by type of product rather than by importing entity;

• exceptional or late deliveries are underestimated;

• the threshold is crossed late in the year, with impact from January 1.

Therefore, the relevant question is not whether you are below the threshold today, but how likely you are to exceed it this year. Above a certain volume (30-40 tons), waiting does not become a neutral choice.

Delivery terms: false security

Delivery terms such as DDP (Delivered Duty Paid) often give a sense of certainty, but in the context of CBAM this is not always justified.

Although the non-EU supplier is responsible for import formalities, in practice it cannot file a CBAM declaration. This creates tensions and ambiguity as to who bears what obligations.

Here it becomes clear that CBAM goes beyond logistics. It also touches on contracts, liability and information flows within the chain.

CBAM liability: how do you organize this internally?

For companies subject to CBAM, the story does not stop with registration. The real challenge is in the organization. Who monitors volumes and CN codes? Who maintains contact with suppliers? And who translates emissions data into financial impact?

CBAM requires that different departments work together and that clear responsibilities are defined. Without that structure, it quickly becomes a reactive process, with information missing or available too late.

Default values or actual emissions?

Many companies start with default values because they are simpler. What is less visible is that these values are often higher and, moreover, increase in the future.

This can have a direct impact on the final cost. So using actual emission data offers potential benefits, but at the same time requires more effort in terms of: complexity of emission data retrieval, verification by approved parties, timing and contractual enforceability.

Here CBAM suddenly becomes a strategic issue: how do you work with your suppliers and how do you record agreements?

"I import finished goods, so CBAM doesn't apply."

Today that reasoning is true in certain cases, but that picture will change. Starting in 2028, the scope of CBAM will expand and the focus will shift from primary materials to more complex products.

This increases reliance on multiple links in the chain and the risk of inconsistent or incomplete information.

"Can't I just pay the fine?"

CBAM fines are more than a financial penalty. They are recorded and shared with European authorities, so non-compliance has longer-term consequences.

That makes it not a one-time consideration, but a structural risk that can affect future audits and your reputation.

Multinational structures: who is responsible?

In international groups with entities inside and outside the EU, CBAM often becomes even more complex. The obligations lie with the entity doing the importing into the EU, regardless of where the information comes from.

This means that this entity remains ultimately responsible, even when it relies on other group companies or external production facilities.