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CBAM Penalties: Not Surrendering Certificates and Importing Without Authorisation

What are the CBAM penalties for not surrendering certificates and for importing without authorisation?

There are two penalties and they are not interchangeable. An authorised declarant that fails to surrender certificates by 30 September pays the EU ETS excess emissions penalty for each certificate not surrendered (Article 26(1)). A person importing without authorisation pays three to five times that amount on the whole year's embedded emissions (Article 26(2) and (2a)).

What the act says

What to do

Sources

Last checked against the act text on 2026-10-20. For information only, not legal advice.

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