Under the CBAM framework, each EU Member State is responsible for its own national implementation of the regulation. While the European Commission oversees central functions including certificate pricing, registry management, and enforcement coordination, each Member State must appoint a competent national authority to handle local procedures.
This chapter first outlines the general design of CBAM and the EU-level responsibilities under CBAM, then maps how Denmark, Finland, and Sweden have structured their national implementation—detailing the institutional setups and designated authorities in each country.
8.1 EU-level
As mentioned earlier, the implementation of CBAM happens gradually starting with a transitional phase before the CBAM regime is fully implemented in 2026. The transitional phase serves as a trial period to gather data and improve on methodologies and there have been no CBAM certificates purchased or surrendered during this phase, however failure to report can still lead to penalties. The reports include direct and (for some) indirect emissions, as well as any carbon price paid in the country of origin. To access the CBAM Registry, the company must be registered as an importer and have an EORI number.
In 2025, CBAM declarants can apply via the CBAM Registry to achieve the status of `authorised CBAM declarant`. Their application is processed by the National Competent Authority of the EU Member State where the importer is established. This status will become mandatory as of 1 January 2026 for the import of CBAM goods into the EU customs territory. The authorisation process involves applying through the EU’s CBAM system and meeting the Regulation criteria including proving the ability to fulfil reporting and compliance obligations.
When the definitive CBAM regime goes into force from January 2026, all importers must purchase and surrender CBAM certificates annually to cover the embedded emissions of imported goods. Only authorised CBAM declarants are permitted to import CBAM covered goods. Each importer will submit an annual declaration (replacing quarterly reports) detailing the emissions embedded in their CBAM covered imports of the previous year and surrender a corresponding number of certificates. Importers can buy CBAM certificates from their national authorities. The price of the certificates will be calculated depending on the weekly average auction price of EU Emissions Trading System (ETS) allowances (€/tonne CO2 emitted) (European Commission, n.d.b). The certificates are from an EU-wide registry, and certificates cannot be traded between companies, only purchased and redeemed via the official platform. If importers can prove that a carbon price has already been paid during the production of the goods, the corresponding amount can be deducted.
The European Commission provides the central electronic systems including the online CBAM Transitional Registration Platform, where all importers are required to register to become a CBAM declarant (access is approved by their national competent authority).
8.2 Denmark
Denmark adopted Act on supplementary provisions to the CBAM Regulation (Law no. 1452 of 10 Dec 2024; L 17), to establish domestic legal basis to implement CBAM (Klima-, Energi- og Forsyningsministeriet, 2024b). The Minister for Climate, Energy and Utilities designate the competent authority and holds core supervisory powers. The designated national competent authority in Denmark is the Danish Energy Agency (Energistyrelsen). However, Denmark has chosen a tripartite division of responsibilities between the Danish Energy Agency, the Danish Business Authority and the Danish Customs Agency, this mirrors the Danish setup for handling the EU Emission Trading Scheme.
Transitional phase
As the national competent authority, the Danish Energy Agency is the lead agency for CBAM in Denmark. In the transitional phase, the Energy Agency’s primary role is oversight of reporting and guidance. It publishes detailed guidelines for importers on how to comply with CBAM reporting requirements and advises companies on methodologies for calculating embedded emissions, instructing importers to use actual production data and providing procedures when data are unavailable (Energistyrelsen, 2024). The agency can access the CBAM registry (as NCA) to monitor Danish importers’ reports and is tasked with verifying the accuracy of reported data. If irregularities or omissions are found, the Energy Agency can issue orders to companies to correct or provide information (Klima-, Energi- og Forsyningsministeriet, 2025a).
During the transitional phase the Danish Customs Agency (Toldstyrelsen) is responsible for sending out notification letters to companies who have imported CBAM covered goods every quarter of the year, the notifications are send via Digital Post (Digital Post is the mail service Danish public authorities use to communicate digitally with citizens and companies). If an importer did not receive a notice for a given quarter, no CBAM report is required for that period (Energistyrelsen, n.d).
It is the Customs Agency that facilitates access to the EU Commission’s CBAM registry and is responsible for providing companies guidance on how to attain access to the EU CBAM registry. Companies need to attain access before they can apply for authorisation as a CBAM declarant (Erhvervsstyrelsen, 2025).
The Danish Business Agency (Erhvervsstyrelsen) is responsible for processing and approving applications to become a CBAM Declarant, it is therefore the Danish Business Agency that provides guidance on how to apply for authorisation. The agency has contacted all companies covered by CBAM directly via Digital Post with instructions for the application module (Energistyrelsen et al., n.d).
The definitive regime
In the definitive regime, The Energy Agency’s continues to handle the technical and regulatory oversight of CBAM and is responsible for control and enforcement. From 1 April 2026, imports (≥ 50 tonnes/year) of CBAM goods will only be allowed if the company is an authorised CBAM declarant or has a pending application. If this is not the case customs will stop further import until the company is improved. Companies that fail to apply beforehand and attempt to import significant quantities of CBAM goods can thus expect their shipments to be stopped at the border (Erhvervsstyrelsen, 2025).
Authorities control and enforcement
After each completed reporting period the Danish Energy Agency receives a list from the European Commission of importers who have not fulfilled their reporting obligation. Failure to fulfil the reporting obligation applies in cases where a CBAM report has not been submitted within the respective deadline, or when the European Commission can demonstrate deficiencies in the report submitted. In both cases, the importer will be contacted by the Energy Agency to prompt submission of the CBAM report or with a view to remedying deficiencies in the submitted report. In the event of repeated failures to meet the reporting obligation, or in cases where the importer opposes remedying its deficient reporting, the Energy Agency may sanction the importer with a fine (Energistyrelsen, 2024).
Company support
Danish authorities have invested in guidance, outreach, and support tools to help companies navigate the new CBAM requirements and are using multiple platforms in their communication efforts – websites, business portals, direct mail, webinars, and helpdesks. The Energy Agency, Customs Agency, and Business Authority have each developed resources in their areas of responsibility, while also partnering on joint guidance initiatives, and they all have established public contact points for CBAM queries (Erhvervsstyrelsen, 2025).
Administrative Fees
Denmark has chosen to establish a system of annual fees for CBAM declarants: the Danish Energy Agency will charge each authorized CBAM importer a yearly fee to cover the costs of administering CBAM. Pursuant to the Act on supplementary provisions to the CBAM Regulation, the Danish government issued Executive Order No. 1500 of 10 December 2024 (Bekendtgørelse nr. 1500 af 10. December 2024), which entered into force on 1 January 2025 together with the Act. This executive order specifies the administrative procedures and financial provisions for Denmark’s implementation of CBAM and sets the fee at DKK 2,760 for the year 2025, and DKK 2,440 from 2026 onwards. The order specifies payment procedures, and that late payment may incur interest and reminder fees (Klima-, Energi- og Forsyningsministeriet, 2024c). This fee mechanism is to ensure that Denmark can fund the necessary compliance monitoring and support tasks as CBAM scales up.
8.3 Finland
In Finland, the Finnish Customs Authority (Tulli) has been designated as the competent authority responsible for the implementation and oversight of the CBAM regulation. Therefore, will the customs authority in Finland act both as customs authority and as the national competent authority (Tulli, 2024a).
Transitional Phase
In 2023, the Finnish Ministry of Economic Affairs and Employment appointed a working group to prepare the implementation of the CBAM regulation in Finland. The working group included participants from several ministries, the energy agency and industry representatives among others (Työ- ja elinkeinoministeriö, 2023).
The Finnish CBAM Implementation Act 2023/956 implemented in 2023 specifies Customs’ enforcement powers, the obligation for importers to obtain authorisation, and the penalties for breaches. Finnish Customs have served as the competent national authority under the Carbon Border Adjustment Mechanism Regulation since January 2024 (Työ- ja elinkeinoministeriö, 2024a).
During the transitional phase Finnish Customs has been responsible for providing guidance for companies including how to access the EU Transitional CBAM Registry, delegate reporting authority, and submit quarterly emission reports. Finnish Customs is also in charge of processing and approving authorization applications to become authorised CBAM declarant. Beginning in early 2025, companies have been urged to apply for the authorized declarant status to avoid any disruption to imports (Tulli, 2025). Companies importing CBAM covered goods are notified that their imports are covered by the CBAM when they receive their customs clearance notice by the Customs Agency (Tulli, 2024b).
Definitive Regime
Finnish Customs is responsible for granting authorised CBAM declarant status, managing importer access to the EU CBAM (Työ- ja elinkeinoministeriö, 2024b). At import, Customs checks whether the goods are within CBAM scope and verifies that the importer holds valid authorisation. Imports by non-authorised declarants are not permitted. Finnish Customs may impose penalties for failure to comply with CBAM obligations (Tulli, 2024a).
Authorities control and enforcement
From the start of 2026, Finnish Customs can carry out audits and enforcement actions to ensure compliance. These include checking annual declarations submitted by authorised CBAM declarants. Audits may involve on-site inspections at company premises, conducted by Customs’ corporate auditors. Finnish Customs is entitled to obtain any information from importers that is required for CBAM supervision under the Regulation. If companies neglect their reporting or other CBAM obligations, Customs is authorised to impose penalties. The penalty structure follows the EU CBAM Regulation and relevant national legislation (Tulli, 2024a).
Company support
Finnish customs have been responsible for providing company guidance. In 2023, Customs set up a dedicated CBAM-information webpage and published instructions in Finnish, Swedish, and English to help importers understand the new requirements, providing guidance for the transitional phase and the definitive regime. Support have included guidance, information events, e-mail newsletters and notifications. Finnish Customs established a helpdesk including an advice line (closed down in September 2025 due to low demand) and a designated email address (Tulli, n.d.).
8.4 Sweden
In 2024, Sweden adopted Act 2024:364 and Regulation 2024:365, containing supplementary provisions to the EU CBAM Regulation. The regulation designates the Swedish Environmental Protection Agency (Naturvårdsverket) as the national competent authority for CBAM, responsible for its implementation and oversight of compliance.
The Swedish Environmental Protection Agency collaborates closely with Swedish Customs in the implementation and execution of CBAM. Swedish Customs (Tullverket) also have responsibilities for the implementation and enforcement of CBAM in Sweden (Sveriges Riksdag, 2024a; Sveriges Riksdag, 2024b).
Transitional Phase
During the transitional phase, the Swedish Environmental Protection Agency provides guidance for companies on CBAM, including how to report CBAM-covered goods, how to apply for CBAM declarant status, and how to calculate actual emissions. The agency is further responsible for ensuring that companies submit quarterly emissions reports as required (Naturvårdsverket, 2025b).
Swedish Customs is responsible for informing companies whether they have reporting obligations under CBAM (Tullverket, 2025b). Importers will receive a notification, when submitting a customs declaration for goods that fall under CBAM, that quarterly carbon emission reporting is required. I Swedish Customs is responsible for managing the technical access to the EU’s reporting systems both the CBAM Transitional Registry and the permanent CBAM Registry. To log in, Swedish importers go through Customs’ e‑service platform (Tullverket, 2025a).
Any importer exceeding the de minimis threshold (which is set to 50 tonnes of CBAM-covered goods per year must be approved as an authorised CBAM declarant. As of 28 March 2025, it became possible for companies to apply for the status of authorised CBAM declarant. The application is submitted digitally via the EU central CBAM Registry. The authorisation process for all companies will be administered by the Swedish Environmental Protection Agency, who is responsible for processing and approving the applications for company importers to become CBAM declarants. The approval includes checks on the company’s compliance record as well as its financial and organisational fitness, in line with EU rules (Naturvårdsverket, 2025b).
Definitive Regime
In the definitive regime, the Swedish Environmental Protection Agency will review the annual CBAM declarations submitted by authorised importers, which detail the previous year’s imports and emissions. The agency verifies that importers surrender the correct number of CBAM certificates corresponding to their declared emissions.
From January 2026 onward, importers will no longer receive notifications regarding the declarant’s reporting obligation. Instead, Swedish Customs will verify whether the goods fall under the scope of the CBAM Regulation and check whether the importer holds an authorised CBAM declarant status. If such status is lacking, importation of the goods will not be permitted (Tullverket, 2025b).
Authorities control and enforcement
As the appointed CBAM authority, the Swedish Environmental Protection Agency monitors and enforce compliance. It carries out audits and inspections of importers’ CBAM reports and declarations, either on its own initiative or at the request of the European Commission. If an importer fails to meet their obligations (such as missing a report, under-reporting emissions, or not surrendering enough certificates), the agency may impose sanction fees in line with EU rules and Swedish law. Non-compliance during the transitional phase may also negatively impact an importer’s application to become a CBAM declarant. The Swedish Environmental Protection Agency may revoke authorised CBAM declarant status in case of abuse or repeated violations, which would prohibit further imports of CBAM goods. To carry out these tasks, the agency cooperates with and receives data from other Swedish authorities (Naturvårdsverket, 2025c).
Company support
Swedish authorities provide extensive guidance to help companies navigate and comply with CBAM requirements. For technical or customs-related queries, Swedish Customs is the first point of contact, while for regulatory or reporting questions, the Swedish Environmental Protection Agency is the responsible authority. This division of responsibilities is clearly communicated so companies know where to turn.
The Swedish Environmental Protection Agency has established a CBAM information hub on its website and provide public contact points, including a telephone helpdesk (Naturvårdsverket, 2025b). Swedish Customs has likewise published practical instructions for importers. Its website offers user guidance for accessing the EU CBAM IT systems, as well as information on how to obtain company import statistics and correctly classify goods (Tullverket, 2025a).
Industry perspectives on CBAM implementation in Denmark, Finland and Sweden
Four interviews were conducted with Industry associations from all three countries, two from Sweden and one from Denmark and Finland. Interviews with industry representatives in Denmark, Finland, and Sweden show broad support for the principle behind CBAM but also highlight significant implementation challenges during the transitional phase. While experiences vary between countries, a clear pattern emerges: the administrative burden, data requirements, and EU-level system shortcomings have posed substantial difficulties in all three countries.
8.4.1 Common experiences across Finland, Sweden and Denmark
All industry representatives stressed that the implementation has been complex, rushed, and resource intensive. The short preparation time, delayed EU guidance, and early malfunctioning of the Commission’s IT systems made compliance challenging for all companies regardless of their size. All described the process as confusing and burdensome, particularly for smaller companies, while Finnish industry characterised the early phase as “extremely challenging” due to unrealistic timelines and technical problems in the EU registry.
A key shared challenge relates to data collection from non-EU suppliers, particularly in China and India. All interviewees noted that suppliers often lacked the knowledge or systems to provide emissions data, significantly increasing administrative burdens. The need to report detailed input data for complex products, such as multi-component machinery, was highlighted repeatedly as a major barrier.
The administrative burden is highest for companies working with complex or downstream products, while basic industries are generally better positioned. Swedish industry emphasised that CBAM is much more difficult for manufacturing sectors handling thousands of components, a view echoed in Denmark, where companies importing steel and aluminium reported difficulties obtaining data from upstream suppliers.
8.4.2 Differences between national implementation models
While the overarching challenges were similar across Finland, Sweden and Denmark, industry representatives highlighted some differences in how national authorities organised their support and handled the early implementation phase. Finnish Customs was highlighted as supportive providing assistance during the difficult early phase. Swedish authorities, particularly the Environmental Protection Agency, were described as well-organised and responsive, offering helpdesks, reference groups, and clear information channels. Danish companies experienced difficulties navigating the tripartite division of responsibilities, with unclear points of contact and long response times. Despite the challenges companies experienced in reaching the correct authority, industry representatives emphasised positive aspects of their collaboration, including authorities actively participating in industry webinars.
8.4.3 Sector-specific and strategic concerns
A general concern companies have raised is the risks of production shifting outside the EU, as finished goods imported from third countries may become cheaper than importing CBAM-covered raw materials. There are also concerns raised on export competitiveness, noting the lack of a functioning export mechanism as free allocations are phased out.
8.4.4 Concluding reflections on industry experiences
Across all three countries, industry actors recognise CBAM as a necessary step toward fair climate regulation but emphasise that successful implementation will require stronger administrative support, clearer guidance and a more reliable EU-level IT infrastructure. Companies stress that the transitional phase has revealed practical challenges that must be addressed before the definitive regime begins — particularly regarding data collection from non-EU suppliers, coordination across national authorities and the unresolved question of export competitiveness as free allowances are phased out.
Overall, industry perspectives underline that compliance alone will not be sufficient; effective CBAM implementation must be paired with policy stability, technological support and dialogue between authorities and businesses to ensure that decarbonisation does not lead to unintended competitiveness risks.