The OECD report had outlined operational guidance and recommendations for EU Member States as the Carbon Border Adjustment Mechanism (CBAM) entered its definitive phase in 2026. It had highlighted the roles of National Competent Authorities and Customs Authorities in authorisation, verification, enforcement and anti-circumvention controls.
The OECD’s 2026 report, “Advancing the Implementation of the EU Carbon Border Adjustment Mechanism: Lessons from Romania” on 30 September 2026, provided practical guidance for National Competent Authorities (NCAs), Customs Authorities and other government agencies as the European Union’s Carbon Border Adjustment Mechanism (CBAM) moved into its full operational phase.
CBAM forms part of the EU’s climate strategy under the European Green Deal and the Fit for 55 package. The mechanism is intended to address carbon leakage by applying a carbon price to selected imported goods corresponding to the carbon cost faced by domestic producers under the EU Emissions Trading System (EU ETS).
The mechanism supports the EU’s objectives of reducing net greenhouse gas (GHG) emissions by at least 55% by 2030 compared with 1990 levels and achieving climate neutrality by 2050.
CBAM entered the definitive phase
CBAM’s transitional period ran from 1 October 2023 to 31 December 2025, during which importers primarily had to report embedded emissions and provide data without financial obligations.
The definitive period started on 1 January 2026, introducing financial and compliance requirements for covered imports.
Importers of CBAM goods must obtain authorised CBAM declarant status. They are also required to submit annual CBAM declarations, have embedded emissions verified by third parties, and purchase and surrender CBAM certificates.
Each CBAM certificate represents one tonne of CO₂e of embedded emissions, with certificate prices linked to EU ETS allowance prices. The surrender requirement is being phased in alongside the progressive phase-out of free EU ETS allowance allocations for EU producers.
Importers can reduce their CBAM certificate obligations where an effective carbon price had already been paid in the country of origin for the emissions generated during production.
Goods covered by CBAM
CBAM applies to emissions-intensive products including iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.
The mechanism also covers selected downstream products, including screws, bolts and structures, to reduce the risk of circumvention.
Certain imports are exempt, including goods below the annual 50-tonne de minimis threshold, military goods, certain waste and scrap, and goods originating in non-EU countries linked to the EU ETS.
Role of national competent authorities
The report had identified NCAs as having a central role in administering and enforcing CBAM.
NCAs assess applications for authorised CBAM declarant status, including applicants’ legal and financial stability. Entities established for less than two financial years are subject to financial guarantee requirements, which NCAs must monitor.
NCAs also oversee accredited verifiers, review annual CBAM declarations, manage CBAM certificate accounts and monitor compliance.
For authorised declarants that fail to surrender the required certificates by 30 September, the penalty is equal to the EU ETS excess emissions penalty of EUR 100/tCO₂e, adjusted for inflation.
Entities making unauthorised imports above the de minimis threshold face penalties ranging from three to five times the EU ETS rate.
Customs Authorities to support border controls
Customs Authorities have been assigned a key role in determining whether imported goods fall within CBAM’s scope and whether the de minimis threshold applies.
They must also verify importer authorisation through TARIC Y-codes and the CBAM Registry.
Customs declaration information, including EORI numbers, CN codes, mass, country of origin and CBAM Account Numbers, is collected and automatically transmitted to the European Commission through SURV3 and to NCAs.
The report also highlighted the need for Customs Authorities to address circumvention risks, including artificial shipment splitting, product misclassification and false origin documentation. Risk profiles for such activities can be incorporated into systems including CRMS2 and ICS2.
Romania’s exposure to CBAM
The report used Romania as a case study to demonstrate the economic and administrative implications of CBAM.
Romania’s production of CBAM goods, excluding electricity, amounted to EUR 4.4 billion in 2023, equivalent to about 1.4% of GDP and approximately 7% of industrial Gross Value Added.
Domestic CBAM production was concentrated mainly in iron and steel, cement and aluminium.
Romania imported EUR 11.5 billion of CBAM goods in 2024. Extra-EU countries accounted for 34% of total import value and 53% of total import quantity.
Among extra-EU imports, iron and steel accounted for 68% of value, followed by fertilisers at 12%, aluminium at 9% and electricity at 8%.
By sector, extra-EU sources accounted for the highest shares of Romania’s imports of cement at 82% and fertilisers at 62%.
Turkey was leading extra-EU origin
Türkiye was Romania’s largest extra-EU origin country for CBAM goods in 2024, with imports valued at EUR 1.6 billion, mainly comprising iron, steel and aluminium.
Other major non-EU origins included Serbia, China, Ukraine and Russia. Ukraine was particularly associated with cement imports, while Russia was a major source of fertilisers.
Romania also exported CBAM goods to extra-EU markets. Such exports totalled EUR 1.7 billion in 2024, representing about 25% of the country’s EUR 6.5 billion in total CBAM exports.
Iron and steel accounted for the largest share, with exports worth EUR 1.1 billion.
OECD recommendations for national implementation
The report had set out 21 recommendations for national authorities covering administrative capacity, authorisation, customs controls, enforcement and governance.
It called for authorities to establish compliance metrics, including measures comparing actual and default emissions and tracking reporting timeliness. It also recommended training officials in carbon accounting and trade rules.
For authorisation procedures, the report recommended automated tools for calculating financial guarantees and clear procedures for revoking authorised declarant status when non-compliance requirements are triggered.
Authorities were also encouraged to develop national penalty rulebooks in coordination with EU ETS teams to ensure consistent treatment of non-compliance and unauthorised imports.
On customs administration, the OECD recommended integrating automated CBAM checks into national customs clearance systems and ensuring interoperability with EU systems such as SURV3 and the CBAM Registry. National authorities were also advised to develop risk profiles targeting potential circumvention.
The report further recommended establishing a national CBAM Interministerial Working Group (IWG) and a Stakeholder Advisory Group. It called for national guidance handbooks and shared dashboards to support coordination and monitor implementation progress.
