One Mechanism, Many Gateways: How CBAM Looks Different Across Europe

Dubrink Updates

By Dubrink

Monday, 09 March 2026

When the Carbon Border Adjustment Mechanism was introduced, it was presented as one of the most harmonised regulatory instruments the European Union had ever built. One regulation. One central registry. One quarterly reporting format. From the outside, it looks seamless.

Spend time working with importers across different Member States and a more layered picture appears. CBAM is European law, but it enters companies through national doors. The regulation may be centralised. The administration is not.

For many importers this distinction barely registers. If you operate in one jurisdiction, you adapt to the local process and move on. But when you compare how CBAM is handled across Europe, the differences are surprisingly nuanced. Not dramatic. Not chaotic. Just distinctly national.

A digital mechanism that begins on paper

CBAM feels digital. The European Commission provides a central registry. Reports are uploaded electronically. Deadlines are aligned across the Union. Yet in several Member States, companies applying for Authorised CBAM Declarant status must first submit documentation physically to their local customs office. Signed forms. Supporting documents. Formal applications delivered in hard copy.

There is something slightly unexpected about that. A mechanism designed to address global carbon leakage through a central European platform often begins with traditional administrative procedures. This is not a weakness. It reflects how CBAM is built on existing customs structures. The portal may be European. The gatekeeper is national.

Romania and the discipline of data reconciliation

Romania provides an interesting example of how authorities shape implementation through practice. To obtain authorisation, companies must have filed their transitional CBAM quarterly reports in a way that precisely matches their customs declarations. Quantities reported under CBAM are expected to align with what has been declared at customs.

For professionals with a strong customs background, this sounds straightforward. Customs data should lead. In reality, many companies rely on ERP systems for internal reporting. The weights and quantities recorded internally do not always perfectly match customs declarations. Small discrepancies can arise for practical reasons. Romania has been notably strict in reconciling those datasets before granting authorisation. The approach reinforces a clear principle. CBAM reporting must reflect customs reality. It is a reminder that CBAM does not sit next to customs. It sits on top of it.

Austria and the unexpected path through EU ETS

To gain access to the CBAM portal in Austria, companies must navigate through the EU ETS access module. For importers that are not themselves subject to the EU Emissions Trading System, this often comes as a surprise. Why speak to an ETS helpdesk if you are not part of the ETS?

From an administrative point of view, the logic is understandable. Authorities build on systems that already exist. For companies, however, it shows how CBAM is integrated into national infrastructures in ways that are not immediately visible from the regulation alone. This structural shift highlights how regulatory friction can emerge from existing national technical frameworks.

The Netherlands and the market for authentication

Access to the CBAM registry in the Netherlands requires authentication through eHerkenning, which is a privatised authentication system. Unlike most Member States where access is handled directly by a public authority, the Dutch model operates through multiple approved private providers. Companies must select a provider, purchase the appropriate level of access, and pay associated fees.

The experience can differ from provider to provider. Pricing models vary. Onboarding processes vary. Even support levels can vary. This makes the Dutch approach unique within the Union. It introduces a market dynamic into what many assume is a purely administrative step. For importers, this means that access to a European climate mechanism depends not only on compliance readiness, but also on navigating a private authentication landscape within the national system.

Belgium and the breadth of digital roles

The Belgian system uses role-based authorisation. The specific role required for CBAM access grants permissions that extend beyond CBAM itself. Service providers acting on behalf of importers may receive access to additional functionalities within the customs system. This does not mean the system is flawed. It reflects how CBAM has been embedded into an existing digital environment.

When a new regulatory layer is added to established platforms, boundaries are sometimes wider than anticipated. For companies that work with representatives, this becomes a practical governance question. Who has access to what, and how broadly? It represents a distinct compliance exposure regarding data security and market access.

When certainty becomes temporary

Perhaps the most challenging aspect of a young mechanism is not structure but interpretation. In Belgium, we experienced a situation that many companies will recognise in different regulatory contexts. A particular procedure was discussed with the competent authority. The proposed approach was confirmed in writing. It was confirmed again. And again.

The previously accepted method was no longer considered valid. The interpretation had shifted. As a consequence, applications had to be revised and in some cases resubmitted. Authorisation processes had to start again. This verification gap and shift in regulatory stance can create significant hurdles for importers aiming for long-term certainty.

Navigating the gateways

CBAM may be one mechanism, but as we have seen, it travels through many gateways. The differences are not dramatic, yet they are real. They shape how companies gain access, how they align data, how they interact with authorities, and how they plan ahead. For businesses operating in a single Member State, these nuances may remain in the background.

For those with cross-border exposure, or those preparing for the definitive phase in 2026, understanding the national layer becomes increasingly important. At Dubrink, we support companies across all 27 EU Member States in managing CBAM in a structured and scalable way. From authorisation and registry access to reporting, reconciliation and automation, we help streamline the process and reduce administrative friction.

Together with Pincvision, we work at the intersection of customs expertise and digital CBAM management. That combination matters in a landscape where regulation is European but implementation is local. If you are navigating CBAM today or preparing for what comes next, feel free to reach out to Pincvision or to us at Dubrink. We are more than happy to guide you through the practical realities behind the regulation.

Executive Takeaways

• Administrative Variability: While CBAM certificates and regulations are centralized, the gatekeeper for registry access and authorized declarant status remains strictly national.

• Customs Alignment: Jurisdictions like Romania require actual emissions data and reporting quantities to reconcile perfectly with customs declarations before granting authorization.

• Access Costs: In certain markets like the Netherlands, importers must navigate a privatized authentication market, introducing commercial fees to the compliance process.

• Regulatory Friction: Shifting interpretations by national authorities, particularly in Belgium, mean that previously confirmed procedures may require resubmission, impacting compliance timelines.