CBAM critical deadline: March 31! Non-compliant companies face risk of blockage

Companies that have not submitted their applications by this date and exceed the annual threshold of 50 tonnes will face the risk of delays and penalties when importing CBAM-covered goods.

The definitive phase of CBAM entered into force on January 1, 2026, and the system now directly impacts customs procedures. The transitional period had been granted by the European Commission due to operational disruptions in system access. However, this period ends on March 31, and companies that fail to complete their applications will not be able to import CBAM goods. Those that submit their applications on time will be allowed to continue imports temporarily until a decision is made; however, retroactive penalties will be applied to rejected applications.

Companies that have not yet applied must quickly engage in the process. During the application, they are required to provide estimated quantities and values of the goods to be imported for the current and following year, along with a declaration confirming that no serious legal violations have been identified in their operations. In addition, it is mandatory to submit a certificate of activity obtained from the tax office and financial statements for the last three fiscal years. Following the application, the CBAM account number or application number must be indicated in the customs declaration.

TARIC codes to be declared in customs declarations are also a critical part of the process. Code Y128 indicates existing authorizations, while code Y238 refers to applications submitted before March 31, 2026, that are still under evaluation.

The competent authority may take up to 120 calendar days to assess applications. Therefore, companies that fail to complete their applications by March 31 will have to wait for a decision before being able to import CBAM-covered goods.

Experts emphasize that March 31 is a critical threshold for companies. Firms that complete their applications on time will be able to manage CBAM as a workable process, while delayed applications may lead to prolonged delivery delays and supply chain disruptions.