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The EU's Carbon Border Adjustment Mechanism (CBAM): Addressing Carbon-Intensive Goods Imported to the EU

By
JAS Sustainability Team
September 25, 2023
The EU's Carbon Border Adjustment Mechanism (CBAM) is a regulatory framework introduced to address carbon leakage by imposing reporting requirements on importers of carbon-intensive goods, promoting transparency, incentivizing lower-emission choices, and leveling the playing field between domestically produced and imported goods.
The EU's Carbon Border Adjustment Mechanism (CBAM) is a regulatory framework introduced to address carbon leakage by imposing reporting requirements on importers of carbon-intensive goods, promoting transparency, incentivizing lower-emission choices, and leveling the playing field between domestically produced and imported goods.

As the European Union (EU) heightens its climate ambitions, there are increasing regulations related to "carbon leakage." This phenomenon occurs when EU-based companies shift carbon-intensive production to countries with less strict climate policies, potentially increasing emissions. To address this, the EU has introduced the Carbon Border Adjustment Mechanism (CBAM), an environmental regulation designed to establish a fair price for carbon emissions associated with the production of carbon-intensive goods entering the EU. Its purpose extends to encouraging cleaner industrial practices in non-EU countries. 

Goods Covered in the Initial Phase: 

The CBAM's scope encompasses products like cement, iron and steel, aluminum, fertilizers, electricity, and hydrogen in the transitional phase. Moreover, there are plans to evaluate the possibility of expanding the range of covered products by 2030, potentially including additional sectors. 

Impacts: 

  • Importers must carefully track and report emissions data for their imported goods. The European Commission is developing IT tools to help importers report and manage this data. 
  • Non-compliance with reporting requirements may result in financial penalties. 
  • The regulation introduces an additional layer of complexity in the import process. 

Timeline: 

As the CBAM unfolds between 2023 and 2035, it will have significant implications for industries, global competitiveness, and the fight against climate change. Here are some key dates to keep in mind: 

  • October 1, 2023: The CBAM enters its transitional phase. Importers of carbon-intensive goods begin reporting embedded greenhouse gas (GHG) emissions. 
  • January 31, 2024: The first reporting period for importers concludes. Flexibility in reporting methodologies is allowed. 
  • January 1, 2025: Reporting using only the EU method becomes mandatory. 

Benefits: 

  • Importers disclosing emissions data enhances transparency about the carbon impact of goods. 
  • The regulation incentivizes importers to choose lower-emission products, driving sustainable choices. 
  • Imported goods are subject to emissions reporting similar to domestically produced goods, leveling the playing field. 
  • The regulation raises awareness about carbon emissions associated with international trade. 

How Can JAS Support You? 

  • EU Import Customs Clearance: Our team of customs experts consult you and assist you in expediting the customs clearance process and the complexity of tariff codes, duties, taxes, and international trade regulations.* 
  • EU Regulation Monitoring: We keep you informed about CBAM updates and evolving regulations, ensuring you remain compliant and adaptable to changes. 

*The importer is at all times responsible for providing all documentation related to customs clearance, including correct shipment/tariff and emission-related data. 

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Parker Hannifin has recognized JAS with its International Freight Forwarder of the Year award for 2025

Once again, Parker Hannifin has recognized JAS with its International Freight Forwarder of the Year award for 2025. Parker Hannifin, a Fortune 250 global leader in motion and control technologies, serves a wide range of industries including aerospace, climate control, filtration, and automation. The company highlighted JAS’s cybersecurity and sustainability efforts, on-time delivery, and commitment to continuous improvement as key reasons for selecting JAS as this year’s recipient.

This marks the third time JAS has been honored with this award, having previously received the recognition in 2017 and 2020. Being named  International Freight Forwarder of the Year once again underscores JAS’s ongoing commitment to delivering customer value, consistent partnership, and excellence in global logistics solutions.

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We would like to remind our customers of the implementation of the Import Control System 2 (ICS2), the European Union’s enhanced pre-arrival safety and security program for cargo entering or transiting through EU Member States, as well as Norway, Switzerland, and Northern Ireland. Effective 1 September 2025, ICS2 became mandatory across all modes of transport—air, ocean, road, and rail. This regulation requires the submission of detailed shipment data via an Entry Summary Declaration (ENS) prior to cargo arrival at the EU border.

What You Need to Know ICS2 is designed to:

  • Strengthen EU border security
  • Enable early risk assessment
  • Facilitate legitimate trade
  • Prevent delays and penalties due to non-compliance

Your Responsibilities as a Shipper or Cargo Owner

To ensure compliance and avoid disruptions, please take note of the following obligations:

Data Submission Requirements

You must provide:

  • A complete and accurate commercial description of each item
  • A valid Harmonized System (HS) code, consisting of at least six digits—though in many cases, EU customs may require eight digits or the full tariff code.
  • A valid Economic Operator Registration and Identification (EORI) number for the EU consignee/importer (and for other parties in the EU where applicable)
  • Full details of all parties involved (seller, buyer, consignor, consignee)

Filing Responsibilities

  • Freight Forwarders/NVOCCs: File ENS at the house bill level.
  • Carriers: File ENS at the master bill level.
  • Consignees: Provide valid EORI numbers to ensure accurate filing.

Non-Compliance Risks Failure to comply with ICS2 requirements may lead to:

  • Shipments being delayed, rejected, or held at EU borders
  • Customs inspections and possible administrative penalties
  • Additional costs related to storage or missed deliveries

Recommended Actions to prepare for ICS2 compliance:

  • Audit your product master data for HS codes and descriptions
  • Standardize commercial invoices and packing lists
  • Validate and integrate EORI numbers into your systems
  • Establish clear communication protocols with your logistics partners
  • Ensure complete shipment data is provided to your freight forwarder in time for ENS filing (e.g., at least 24 hours before vessel loading for ocean freight).

Technology & Support

In response to the EU’s Import Control System 2 (ICS2) requirements, we want to reassure our customers that our experienced staff and systems are fully prepared to manage the necessary data submissions and compliance procedures on your behalf. To support this service and ensure the smooth processing of your shipments, a compliance handling fee will apply. This fee covers the administrative effort and data validation to meet the latest EU regulations efficiently and accurately.


We are also investing in digital tools and customs platforms to automate data validation and submission, reducing manual errors and ensuring timely compliance. If you have any questions or would like guidance on preparing your shipment data, please contact your JAS account representative.

JAS has been awarded a Silver Medal in the EcoVadis sustainability assessment, achieving a score of 75 points.

JAS has been awarded a Silver Medal in the EcoVadis sustainability assessment, achieving a score of 75 points. This marks a 15-point improvement from last year’s Bronze rating and places JAS among the top 15% of companies assessed globally.

EcoVadis is one of the world’s most trusted providers of business sustainability ratings, evaluating over 130,000 companies across four categories: Environment, Labor & Human Rights, Ethics, and Sustainable Procurement.

In the latest assessment, JAS received particularly strong recognition in the Environment category (91/100), reflecting our focus on decarbonization, responsible resource use, and advancing sustainable logistics solutions. JAS also recorded solid progress in Labor & Human Rights, Ethics, and Sustainable Procurement, showing how JAS is working to embed responsible practices across its global operations and supply chain.

Andrea Goeman, SVP Sustainability, JAS, commented:

“We are proud to see our progress recognized with the EcoVadis Silver Medal. This achievement reflects the collaboration across our global teams and our strong commitment to building a more sustainable future for our customers, partners, and communities. While this is an important milestone, we will continue to strengthen our practices to further improve our performance in the years ahead.”

With a score of 75 points, JAS now ranks in the 92nd percentile of all companies assessed by EcoVadis. This performance not only supports many of our customers’ supplier selection and evaluation processes, but also highlights the steady progress we are making year over year.

As JAS continues its sustainability journey, the company remains focused on driving measurable improvements across its operations and working closely with customers and partners to reduce environmental impact and achieve shared sustainability goals.

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