The EU Carbon Border Adjustment Mechanism entered its definitive regime on 1 January 2026. For carbon-intensive materials crossing into the EU, Michael's ARCO module checks CBAM obligation automatically, against the covered goods list and your declarant authorisation.
Why It's Not Optional
The definitive CBAM regime is now in force. This is no longer a transitional reporting exercise.
Cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Each ties to specific HS codes.
Per importer per calendar year. Cumulative net mass across covered goods other than electricity and hydrogen (2025 Omnibus simplification). If you cross it at any point in the year, every import that year is in scope.
A pre-screen, not a ruling. ARCO screens swaps against published regulatory and sanctions lists and gates the workflow on the result. It is not a legal determination, a regulatory filing, or a substitute for your compliance function's formal sign-off.
How ARCO Handles It
CBAM has no public REST API. The registry is a web portal that needs EU Login authentication. ARCO works around this with a three-step check at onboarding and at swap time.
At counterparty onboarding, ARCO needs the upload of a valid CBAM declarant authorisation certificate.
SOURCE: CBAM REGISTRY (EU LOGIN PORTAL)At swap gating, ARCO verifies the commodity's HS/CN code against the static CBAM-covered goods list.
CATEGORIES: HS 2523, 72/73, 76, 31, 2716, 2804.10ARCO keeps a cumulative count of the covered-goods volume the importer transacts on the platform in the calendar year. It checks the count against the 50 tonnes per-importer annual de minimis. It flags any resulting CBAM declaration obligation in the document generator. The count covers platform-transacted volume only. ARCO cannot see imports made outside the platform. Your compliance team adds those to establish the importer's true annual CBAM position.
EXPIRY: 72 HOURSWhat You'll See
Platform-tracked volume under the annual de minimis for the importer's calendar year. Or a valid declarant authorisation on file, with the obligation flagged.
Goods code match found. The declarant authorisation is not yet verified. Or the threshold calculation needs manual review.
Covered goods above threshold with no valid CBAM declarant authorisation on file.
Coverage Detail
| Check | What's verified | Refresh cycle |
|---|---|---|
| Declarant authorisation | Valid CBAM authorisation certificate on file | At onboarding + renewal tracking |
| CN code match | Goods code against static CBAM-covered list | On publication (static list) |
| Threshold check | Annual de minimis: 50 tonnes per importer per calendar year, cumulative net mass. ARCO counts platform-transacted volume only. It cannot see imports outside the platform. | Per swap, with regulatory change monitoring |
| Regime updates | Scope expansion or threshold changes (e.g. 2025 Omnibus Simplification) | EC DG TAXUD feed monitoring |
Related Compliance
Request a walkthrough and see a CBAM check run in the demo.