The letter reporting a deviation from regulation (EU) 2023/956 (MACF regulation), which has been sent out since April 2025, is an official reminder that :

- all tasks relating to the transitional period (2023-2025) are to be carried out via the transitional MACF register,

- those relating to the effective period (from 2026) must now be processed in the MACF 2.0 (or "definitive") register, under EORI SIREN, and

- late importers have a short deadline to regularize their situation(douane.gouv.fr).

To put it plainly: if you have imported MACF goods since October 2023 without having filed your quarterly reports, the authorities are asking you to do so within 60 days.

You are if :

• You import products associated with the following sectors: steel, aluminum, fertilizers, cement, hydrogen or electricity (check whether your imports are covered by our MACF checker).
• Your cumulative imports exceed (or will exceed) 50 tonnes / year - the new threshold proposed by the Omnibus Package(Omnibus - douane.gouv).
• You do not yet have "Authorized MACF Declarant" status , which is mandatory to continue importing from January 1ᵉʳ 2026 and which you can request via the definitive MACF register (or "MACF 2.0 register")(taxation-customs.ec.europa.eu).

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The transitional period runs from the end of 2023 to the end of 2025, and is designed to prepare all stakeholders (European importers, non-European suppliers, etc.) for the definitive implementation of the MACF from 2026. During this period, European companies covered by the MACF must report the carbon emissions of imported products on a quarterly basis via a dedicated online portal (the transitional MACF register).

From 2026 and the start of the effective MACF application period, MACF declarations will have to be filed on the definitive register (or MACF 2.0 register), as distinct from the transitional MACF register. In addition, it is via this definitive register that importers must, from March 2025, apply for "authorized MACF declarant" status, which is essential if they are to continue importing products from 2026 onwards.

• Transitional period (until the end of 2025) :
  
  • 10 to €50 per undeclared or under-declared tonne CO₂e.
  • Suspension of processing of your application for "MACF authorized declarant" status.

• Final period (from 2026) :
  
  • Impossible to import without obtaining "MACF authorized declarant" status.
  • Payment of certificates + additional penalties provided for in the implementing regulations 2025/486.

1. Identify your CN codes and 2023-2024 volumes (export an extract from DELTA I/E).
2. Get an EORI SIREN number if you don't have one.
3. PAE form for MACF 2.0 account opening (appendix 1 of DGDDI note)(douane.gouv.fr).
4. EU Login + internal/external delegation.
5. Consolidate emissions data (direct and indirect).
6. Submit Quarter(s) report (XML format or manual interface).
7. Keep proof of audit (future COFRAC verifications).

Keewe automates steps 3→6 thanks to its customs expertise and mastery of carbon calculation methods.

Quel format pour le rapport ?
Document XML selon le format officiel demandé par le Commission Européenne, ou saisie manuelle si < 20 lignes de données (legifrance.gouv.fr).

Can I still use the default values?
No, they are no longer allowed as of Q3 2024.

What if my suppliers refuse to hand over their data?
Document the "due diligence"; without proof of effort, the penalty will apply(natlawreview.com).

Book a 30-minute MACF flash audit with our Keewe experts here.