New TARIC codes for CBAM – what changes from 1 January 2026 and why importers need to prepare today

From January 1, 2026, the Carbon Border Adjustment Mechanism (CBAM) will enter its target phase. The transition period based solely on reporting ends, and the phase of actual financial and customs consequences begins. One of the least media-friendly, yet most critical, elements of this change is new codes on the customs declaration related to CBAM, which will become a mandatory element of every customs declaration for goods covered by the mechanism.

For many companies this will be a turning point – not because of the new reporting burden, but because CBAM is "built in" to the customs procedureCustoms clearance is no longer a neutral logistical step, but a point of regulatory compliance verification.

CBAM in 2026

CBAM was established by Regulation (EU) 2023/956 as a complementary instrument to the EU ETS. Its aim is to prevent carbon leakage by requiring imports of selected goods from outside the EU to bear a CO₂ emission cost comparable to that of EU producers.

A transition period was in effect from October 2023 to the end of 2025, during which importers reported quantities and embedded emissions but did not incur financial costs. From 2026, the situation changes:

• is required Authorized CBAM Declarant status,

• an obligation arises purchase and redemption of CBAM certificates (postponed to February 02.2027),

• and compliance with CBAM is verified already at the customs declaration stage.

This is where the new TARIC codes come in.

What are the new TARIC CBAM codes?

The new TARIC codes do not expand the commodity scope of the CBAM. They do not add new products to the mechanism. Their role is different – technical and enforcement.

These are special conditional codes that:

• must be indicated in the customs declaration,

• inform the customs administration about the importer's CBAM status,

• enable automatic communication between customs systems and the CBAM register,

• decide whether the goods will be allowed to be traded in the EU.

In other words: without the correct TARIC CBAM code, customs clearance may be blocked, even if the goods are correctly tariff classified and subject to zero duty.

Key TARIC codes and their meanings

Codes related to importer status

The most important codes relate to the status of the importing entity:

Y128 – used when the importer has the status of Authorised CBAM Declarant and an active CBAM account number.
This is a "green light" for clearance – the customs system confirms that the importer meets the CBAM requirements.

Y238 – used in a temporary situation when the importer has submitted an application for CBAM status but the decision has not yet been issued.
This code is especially important in early 2026, when many companies will be finalizing the authorization process.

Y237 – indicates that the goods are of EU origin. In such a case, the CBAM does not apply, even though the CN code in question may, in principle, fall within the scope of the CBAM.

Exemption and exclusion codes

A separate category consists of codes for specific exclusions:

Y134 – territorial exemptions (including Büsingen, Helgoland, Livigno).
Y135 – goods intended for military purposes.
Y136 – specific cases of electricity or hydrogen linked to the economic zones of EU countries.
Y137 – key de minimis code, used when the importer does not exceed the threshold of 50 tonnes of CBAM goods per year.

This last code is of particular interest because its misuse may lead to serious sanctionsThe 50 tonne threshold is calculated annually, at the importer level, not at the individual shipment level.

Why are the new TARIC codes so operationally important?

To date, CBAM has primarily focused on ESG, compliance, and environmental reporting. From 2026. enters the harsh customs reality.

In practice this means that:

• Customs agents must know the client's CBAM status before making a declaration,

• Customs and tax departments must collaborate with ESG teams,

• ERP systems and CN/TARIC databases require updating,

• Errors in TARIC codes may result in delivery delays, demurrage costs and even administrative penalties.

CBAM is no longer an "after-the-fact report." It becomes condition for admitting the goods to trading.

The most common risks we observe among importers

From a consulting perspective, four problems arise most frequently:

1. Importer qualification unclear – especially with indirect customs representatives.

2. Automatic application of code Y137, without ongoing control of annual volumes.

3. Data inconsistency between customs systems and the CBAM register.

4. Starting the CBAM Declarant authorization process too late.

Each of these risks could result in real operational consequences as early as the first weeks of 2026.

What should importers do now?

Companies importing goods covered by CBAM should consider the new TARIC codes as a warning sign that the preparatory period is coming to an endIn practice, this means the need to:

• confirmation of who in the organization is the importer within the meaning of CBAM,

• submitting an application for Authorised CBAM Declarant status (if it has not been submitted yet),

• updating customs instructions and TARIC data,

• implementation of the 50-ton threshold control,

• training of customs, purchasing and logistics teams.

Summary

The new TARIC codes for CBAM are not a cosmetic technical change. They are an enforcement mechanism that directly links climate regulations to customs clearance. For importers, this means considering CBAM not only in terms of ESG but also operational risk and supply chain continuity.

Companies that adapt their processes early enough will navigate 2026 smoothly. Those that ignore the role of TARIC codes may learn the hard way that CBAM is no longer the future—it's the present.