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The CBAM Transitional Phase (2023–2025): What SA Exporters Reported

The CBAM transitional phase ran from October 2023 to December 2025. During this period, EU importers were required to submit quarterly reports on embedded emissions — but no financial payments were required.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

The CBAM Transitional Phase (2023–2025): What SA Exporters Reported

The CBAM transitional phase was a critical learning period for both EU importers and their non-EU suppliers. Understanding what happened during this phase — and what data was collected — is important context for SA exporters navigating full enforcement.

Timeline of the Transitional Phase

| Date | Event | |------|-------| | October 1, 2023 | CBAM transitional phase begins | | January 31, 2024 | First quarterly CBAM report due (Q4 2023) | | April 30, 2024 | Second quarterly report due (Q1 2024) | | July 31, 2024 | Third quarterly report due (Q2 2024) | | October 31, 2024 | Fourth quarterly report due (Q3 2024) | | January 31, 2025 | Fifth quarterly report due (Q4 2024) | | December 31, 2025 | Transitional phase ends | | January 1, 2026 | Full enforcement begins — financial payments required |

What Was Reported

During the transitional phase, EU importers submitted quarterly CBAM reports covering:

  1. ▸Product identification — CN code, description, country of origin
  2. ▸Import quantities — Tonnes imported per quarter
  3. ▸Embedded emissions — Direct and indirect emissions per tonne (actual or default)
  4. ▸Carbon price paid — Any carbon price paid in the country of origin (e.g., SA carbon tax)

The Data Legacy

The transitional phase generated a significant dataset that the European Commission is using to:

  • ▸Calibrate the default emission values for each sector and country
  • ▸Identify high-risk importers for enhanced scrutiny
  • ▸Assess the effectiveness of the carbon price deduction mechanism
  • ▸Prepare for Phase 2 sector expansion

SA exporters whose EU customers submitted complete and accurate transitional phase reports are in a stronger position for full enforcement, as their data is already in the EU CBAM Registry.

Addressing Transitional Phase Gaps

If your EU customers failed to submit complete transitional phase reports, or if the data submitted was incomplete or inaccurate, it is important to address this proactively. The European Commission has indicated that transitional phase data will be used to assess compliance risk in the full enforcement phase.

For assistance with transitional phase gap analysis and remediation, visit the Digital Product Passport Registry.

Frequently Asked Questions

What was the CBAM transitional phase?
The CBAM transitional phase ran from October 1, 2023 to December 31, 2025. During this period, EU importers of CBAM-covered goods were required to submit quarterly reports on the embedded emissions in their imports, but no financial payments (CBAM certificates) were required.
Did SA exporters need to do anything during the transitional phase?
SA exporters were not directly required to submit reports, but their EU customers (importers) needed embedded carbon data from them to complete the quarterly CBAM reports. SA exporters who provided this data were better positioned for the full enforcement phase.
What happened if an EU importer failed to submit transitional phase reports?
EU importers who failed to submit transitional phase reports faced penalties under national law in their EU member state. The European Commission also flagged non-compliant importers for enhanced scrutiny in the full enforcement phase.
What data was collected during the transitional phase?
EU importers reported: (1) the quantity of CBAM-covered goods imported, (2) the country of origin, (3) the embedded direct and indirect emissions, and (4) any carbon price paid in the country of origin. This data is now being used to calibrate the full enforcement system.
Is it too late to address gaps from the transitional phase?
If your EU customers failed to submit complete transitional phase reports, it is important to address this proactively. Engage a CBAM compliance specialist to assess any gaps and develop a remediation plan before the first certificate surrender deadline in September 2027.
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