• Carbon tax to be imposed on importers of cement, iron, steel, aluminium, fertilisers, electricity, and hydrogen under the Carbon Border Adjustment Mechanism

A new regulation on the import of energy-intensive goods from countries outside the European Union (EU) enters into force on 1 January 2026. It implements the Carbon Border Adjustment Mechanism (CBAM), introduced two years ago for the EU customs territory. The mechanism sets out the rules for imposing a carbon tax at the border on imports of certain products originating in third countries (non-EU countries), in the form of the purchase of emission certificates.

The idea of this mechanism is that once European companies pay for their carbon emissions when producing goods, importers should also be taxed, in order to ensure fair competition. The aim is to reduce global carbon emissions by encouraging operators in third countries to reduce emissions.

Importers of cement, iron, steel, aluminum, fertilizers, electricity, and hydrogen from non-EU countries are affected, and from 1 January 2026 they will not be able to carry out their activities if they do not have the status of “Approved Declarant”. Companies importing the specified goods from non-EU countries need to take steps before the national competent authority – the Executive Environment Agency for (EEA) – to acquire the status of “Approved Declarant”.

In the coming months, the Ministry of Environment and Water will provide timely information about each subsequent stage of the implementation of the Carbon Border Adjustment Mechanism in Bulgaria. After acquiring the status of “Approved Declarant”, importers of cement, iron, steel, aluminum, fertilizers, electricity and hydrogen will have to indicate how much carbon dioxide (CO2) was emitted during the production of the imported goods, as well as provide information on how this amount was calculated. For each declared amount of emissions, they will have to purchase a corresponding number of certificates. Their price will be determined by the European Commission and will be linked to the price of pollution permits paid by European companies.

The ETS covers all companies that import goods from a third country into the customs territory of the EU. Only imports from countries that participate in the European Emissions Trading Scheme (ETS) or are linked to it are excluded from the application of the ETS. Currently, these are the countries Iceland, Liechtenstein, Norway and Switzerland, as well as the following territories: Bösingen, Heligoland, Livigno, Ceuta, Melilla.

No postponement or flexibility in the application of this mechanism for Bulgaria is foreseen, as well as no relief or transitional mechanisms for Bulgarian importers. For this reason, the EEA is planning a series of meetings with industry organizations in order for their members to be assisted in the effective implementation of the mechanism in Bulgaria. In order to overcome the challenges facing Bulgarian operators, the participation of representatives of the agency in technical and expert groups, organization of activities aimed at personnel, etc. is also foreseen.

Here is what importing companies should do:

First, registration in the system is required, which is carried out by the Executive Environment Agency at the Ministry of Environment and Water. EEA is the national competent authority for this registration and each importer of the specified goods within the scope of the mechanism is required to provide the following information to EEA:

• EORI number - used by the Customs Agency to identify companies. If one is missing, each company must obtain one through the Customs Agency website or by submitting an application;
• Company name;
• E-mail address with which it is registered in EU Login - this is a pan-European profile for access to the CBAM platforms with a single email address and password.

This is all that is needed to register, for which no documents are required at this stage.

The second step is to apply for the status of "Approved Declarant" under the CBAM. Once the EEA has registered on the mechanism platforms, an application for the status of "Authorised Declarant" can be made via the following link: https://cbam.ec.europa.eu/authorised-declarant.

Detailed information on the steps, including the required documents to be attached to the application for the status of "Authorised Declarant", is published on the EEA website at https://eea.government.bg/mehanizam-za-korekciya-na-vaglerodnite-emisii-na-granicite Questions on obtaining the status of "Authorised Declarant" can be sent to cbam@eea.government.bg