From 1 January 2026, the Carbon Border Adjustment Mechanism (CBAM – also known as MACF in French) will enter its definitive phase, marking a major step in the implementation of the European Union’s carbon pricing framework for imports.
As a reminder, this new phase will significantly reshape compliance requirements for companies importing CBAM-covered goods into the EU.
Below is an overview of the main obligations applicable as of 1 January 2026.
Key changes to CBAM obligations
From this date onwards:
Importers bringing in less than 50 tonnes per year of CBAM-covered goods (excluding electricity and hydrogen) will no longer be subject to CBAM obligations,
Annual CBAM reports will replace quarterly reports. These annual declarations must be submitted no later than 30 September 2027,
CBAM certificates relating to imports made in 2026 will only need to be purchased from February 2027 onwards,
Verification by an accredited third-party verifier will not be required where default values are used, provided that the applicable markup is applied.
These changes aim to simplify compliance for lower-volume importers while maintaining robust carbon accounting for larger operators.
Reminder: Authorised CBAM declarant status is mandatory
Importers of CBAM goods exceeding 50 tonnes per year must already take action.
They are required to obtain the status of Authorised CBAM Declarant before 1 January 2026 (as detailed in our article published on 21 October 2025).
The administration has announced a tolerance period during the first quarter of 2026 for companies that have already submitted their application and are awaiting formal approval. However, submitting the request in advance remains essential to ensure continuity of import operations.
How RM Boulanger can support you
RM Boulanger supports companies throughout their CBAM compliance journey, helping them anticipate regulatory changes and secure full conformity with EU requirements.
Our teams can assist you with:
Preparation and submission of quarterly reports,
Regularisation of all pending reports not submitted since Q4 2023,
Estimation of CO₂ emission volumes.
Need guidance on CBAM?
Do not hesitate to contact RM Boulanger for further information or tailored support regarding CBAM obligations.
Our experts are ready to help you navigate the transition to the definitive CBAM regime with confidence.
