The new MACF regulation requires European importers to declare the carbon emissions of products purchased from outside the European Union (EU).
The aim of this climate standard is to subject imports to carbon pricing equivalent to that imposed on goods produced in the EU. From 2026 onwards, importers will have to purchase MACF certificates to offset any difference in carbon pricing between the exporting country and the EU.
To prepare this MACF declaration, the importer must collect information from the supplier. In this article, we explain how to make your MACF declaration.
The first step is to check whether the imported products are covered by the regulations. You can do the test with our MACF checker, available here.
How do you declare your MACF imports?
The MACF transition period runs from October1, 2023 to December 31, 2025, and gives European importers and their suppliers a chance to get up to speed before the regulations are finally implemented in 2026. During this transition period, you will be able to make your declaration quarterly by accessing the MACF register via your account on the French customs website (douane.gouv.fr).
What is the MACF register?
The MACF temporary register is the online portal developed by the European Union on which Importers must file their MACF declarations.
For French importers, the MACF register can be accessed by logging on to the French customs website. The procedure to follow is detailed below (you can also find it on the customs website here):
- Step1: Create an account on the douane.gouv.fr website
- 2ème Step: Make sure your douane.gouv.fr account is certified – if not, you have two options:
- Ask your "company correspondent" to certify the account internally.
- Ask your Pôle d'Action Économique - PAE - to certify your account (identify your PAE by clicking here).
- Step3: Connect to the European MACF portal and follow the steps on the home screen to access your area:
How do I complete my MACF declaration?
To complete your MACF declaration, follow the steps below:
1. Identify MACF products among imported products
Imports must belong to specific categories of goods in the CBAM sectors: Iron & Steel, Aluminum, Cement, Fertilizers, Electricity and Hydrogen. If you want to find out if you are affected by CBAM, you can use our CBAM checker here.
2. Collect the data needed to calculate carbon emissions (e.g. production processes applied, materials used, etc.).
To be able to calculate the emissions linked to the production of imports accurately and rigorously, we need to know a great deal of data. For example, it is necessary to know the production processes applied, as the associated carbon emissions differ.
In steel production, for example, we can distinguish betweenblast furnaces and electricfurnaces, whose emissions are significantly different for the same quantity of steel produced.
In addition, we are interested in the materials (precursors) used in the production of a MACF product, in particular to take into account the emissions associated with these precursors. This is a non-exhaustive list of the issues involved in data collection. Keewe offers its services to help you navigate these new carbon regulations.
3. Calculate direct and indirect carbon emissions
Emissions must be calculated according to specific reporting methodologies, which can be found at this link: As a reminder, scope 3 (indirect emissions) is partially included in MACF reporting. Thus, information linked to precursors (inputs) must appear in the reporting, but no data on the transport (freight) of products to the importer is required.
4. Prepare the MACF declaration in the format required by the European authorities
Once the data has been collected and the emissions calculated, the MACF declaration must be prepared in a precise format defined by the regulations.
5. File the declaration with the European Union's MACF register
Practical questions about the MACF declaration
What is the main difficulty in making a MACF declaration?
To prepare the MACF declaration, the declarant must collect and process a large amount of data, which highlights several challenges:
- Identification and transmission of technical data from suppliers, concerning various aspects of their production processes
- Calculation of direct and indirect emissions according to methods accepted by the EU
- The transmission of all data through the MACF register before the filing deadline (the end of the month following the end of the quarter covered by the declaration - for example, the deadline for filing the declaration for Q1 2024 (January-February-March) is April 30, 2024).
Preparing the MACF declaration therefore depends on a number of factors, such as the relationship between importers and suppliers, and mastery of carbon emissions calculation methods.
How long does it take to make a MACF declaration?
Estimating the time needed to prepare the MACF declaration is difficult, as it depends on a number of criteria, including :
- the number of different MACF products imported
- the number of suppliers from which MACF products are imported
- the method chosen to calculate emissions
- etc.
One of the key success factors is the ability to easily collect data from suppliers, precise information that not all of them are used to communicating.