CBAM Declaration

We inform you that the Ministry of Finance - CBAM and Green Taxes Department has published a report regarding the obligations related to the Carbon Border Adjustment Mechanism (CBAM), during the definitive application period of the mechanism.

For companies that carry out imports of goods falling under the CBAM, the main deadlines and obligations are as follows: The CBAM declaration will be submitted annually, by the date of September 30 of each year, for imports made in the previous year. Thus, the first CBAM declaration will be submitted by September 30 2027, for imports made in the year 2026.

Starting from February 1, 2027, the central platform administered by the European Commission for the purchase and redemption of CBAM certificates will become operational. Also, by September 30, 2027, the number of CBAM certificates related to imports made in 2026 must be returned, as determined by the CBAM declaration.

For imports made in 2026, the price of the CBAM certificates will be the quarterly price set by the European Commission for the quarter in which the imports were made. In case of an excess of certificates purchased for imports from 2026, redemption of these may be requested, under the conditions mentioned by the Ministry of Finance, until October 31 2027.

Important for imports starting from the year 2027: at the end of each quarter, the authorized CBAM declarant must hold in their account in the CBAM Register a number of certificates corresponding to at least 50% of the emissions embodied in the imported goods since the beginning of the calendar year. Attention - importers of clinker and hydraulic cement For products classified under the codes NC 2523 10 00 and 2523 90 00, four new TARIC codes have been introduced, applicable retroactively from January 1, 2026:

• 2523 10 00 10 - White clinker
• 2523 10 00 90 - Other clinker, including gray clinker
• 2523 90 00 10 - White hydraulic cement
• 2523 90 00 90 - Other hydraulic cements, including gray hydraulic cement.

Affected companies must consider revising the registered import customs declarations starting from January 1, 2026 and utilizing the new TARIC codes both in current and future customs declarations, as well as in the annual CBAM declaration.

Using the correct code influences the default values of emissions and, implicitly, the number of CBAM certificates that must be returned. We recommend companies that carry out imports subject to CBAM to verify in advance the classification of imported products and to take into account the financial impact of purchasing CBAM certificates in their budgets for the upcoming period.