Since the introduction of the Carbon Border Adjustment Mechanism( CBAM), companies have had to adapt their import strategies to comply with this new carbon tax introduced by the European Union. But what are the key CBAM dates, and how can you anticipate your CBAM reporting obligations? Let's decipher together the major deadlines of this unavoidable calendar.
CBAM: What is a progressive schedule and why?
Before diving into the MACF carbon deadlines, let's briefly recall its objective. The MACF is a regulatory mechanism designed to adjust the carbon price of imports from countries with lower environmental standards than the EU.
The European Union has decided to introduce a gradual timetable to enable companies to adapt smoothly to the new regulations. In other words, the MACF will not apply immediately to all imports, nor in its final form.
This phasing is essential, as it gives companies time to structure their compliance, adapt their MACF declarations, and optimize their strategy in the face of this EU carbon tax.
Since then, the MACF Carbon has been officially in place, albeit in a transitional form.
- Who is affected? All companies importing high-carbon-impact products such as steel, aluminum, cement, hydrogen, fertilizers and electricity.
- What obligations? No carbon tax to pay yet, but quarterly MACF declarations detailing the carbon emissions associated with imported products.
The idea is clear: to familiarize importers with the system before introducing the financial component of the Border Carbon Adjustment Mechanism.
The companies concerned had to submit their first quarterly report covering imports in the last quarter of 2023.
- Mandatory declaration of carbon emissions from imported products.
- Penalties for non-compliance, even if payments are not yet due.
This date marks a turning point for companies, who must now integrate the MACF declaration into their administrative processes.
The year 2025 marks a key stage in the MACF's ramp-up, with the introduction of new administrative obligations and the structuring of the compliance system. Several critical dates will mark this year for companies subject to the Border Carbon Adjustment Mechanism.
🔹 January 1, 2025: MACF declarant status obtained
From this date onwards, all importing companies concerned will have to be registered as MACF declarants with the competent EU authorities.
- Compulsory procedures: Application to the MACF platform designated by the European Commission.
- Administrative validation: Allocation of a MACF identification number for quarterly declarations.
- Consequences of non-registration: Impossibility of importing products covered by MACF and exposure to penalties.
🔹 Quarterly MACF declarations: deadlines to be met in 2025
As in 2024, companies will still have to submit reports detailing the carbon emissions of their imports. Here are the key dates for quarterly submissions in 2025:
- January 31, 2025: Filing of the 4th quarter 2024 declaration (October-December 2024 period).
- April 30, 2025: Filing of 1st quarter 2025 return (January-March 2025 period).
- July 31, 2025: Filing of 2nd quarter 2025 return (April-June 2025 period).
- October 31, 2025: Filing of 3rd quarter 2025 declaration (July-September 2025 period)
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💡 Reminder: Failure to declare on time exposes the importer to administrative penalties and increased surveillance by the authorities.
🔹 Mid-2025: Reinforced audits and controls
The European Union plans to tighten controls on declared data to avoid any underestimation of carbon emissions from imported products.
- Sampling of companies for in-depth audit.
- Verification of emission calculation methods provided by importers and their suppliers.
- Penalties for non-compliance or deliberate omission of information.
🔹 Autumn 2025:Publication of final rules for 2026
In autumn 2025, the European Commission will publish the final MACF rules for its full entry into force in 2026:
- Definition of definitive calculation methodologies for product carbon emissions.
- Clarification of the mechanisms for purchasing and managing CBAM certificates, which will be mandatory from January 2026.
- Adjustment of thresholds and product coverage, based on data collected during the transition phase.
The year 2025 is therefore a pivotal time for companies affected by border carbon taxes. Anticipating and complying with these initial deadlines will be essential to avoid legal and financial risks from 2026 onwards.
This is the most critical date on the calendar. From now on :
- Companies will have to purchase CBAM certificates to cover the carbon emissions associated with their imports.
- The price of these certificates will be indexed to the European carbon market (EU ETS).
- Importers will have to prove that they have covered all the emissions from their products via these certificates.
In other words, the MACF becomes a true carbon tax at the border, imposing an additional cost on importers of goods with a high carbon footprint.
Faced with this MACF timetable, it's imperative that companies prepare ahead of time. Here are the three key steps to ensure a smooth transition:
1. Implement rigorous import monitoring now
✅ Identify impacted products: Take stock of your supply chain to identify materials subject to MACF declaration.
✅ Collect data on carbon emissions:Your suppliers must be able to provide accurate information on the carbon intensity of their products.
✅ Automate MACF reporting: Digital solutions exist to facilitate quarterly reporting and avoid errors.
2. Assessing the financial impact of the EU carbon tax
✅ Simulate the cost of CBAM certificates: In 2026,importers will have to buy certificates to cover the emissions from their products. It's best to anticipate these costs today.
✅ Optimize purchasing: Favoring suppliers already committed to decarbonization helps reduce the impact of MACF.
✅ Exploring alternatives: Relocation or sourcing from countries with a carbon tax compatible with the European system could be a winning strategy.
3. Communicate and promote your commitments
✅ Reassure your partners: Showing that your company understands the challenges of the Border Carbon Adjustment Mechanism strengthens your credibility.
✅ Highlight your CSR commitment: MACF carbon compliance can be a commercial asset if well communicated.
✅ Working with experts: specialized platforms like Keewe support companies in their transition to more sustainable finance and international trade.
The year 2025 marks the last year of the MACF transition period. This is a critical phase in which companies need to structure themselves before the mechanism comes fully into force in 2026. With mandatory quarterly declarations, tighter controls and the publication of the final MACF rules, it's essential not to wait to get ready.
To remember:
📅 2025: Last year of transition → Compulsory registration, reinforced audits and publication of final rules.
📅 January 1, 2026: Full entry into force → Purchase of CBAM certificates and real financial impact.
📅 2026-2034: Progressive piloting period → Potential extension of products covered and adjustments to obligations.
Preparing for the MACF carbone means not only avoiding penalties, but also optimizing your competitiveness in a world in transition to a low-carbon economy.
🔎 How to prepare effectively?
At Keewe, we support companies in their MACF compliance by providing automated monitoring and reporting tools, expert assistance with MACF declarations, and ongoing regulatory monitoring to anticipate future developments.
💡 With Keewe, control your MACF compliance and avoid penalties.
📩 Need personalized support? Contact us today.