How to respond to the Directorate General for Energy and Climate (DGEC) letter regarding CBAM?
Everything you need to know to comply with CBAM before the deadline, avoid a €50/tonne fine, and turn the obligation into a strategic advantage.
The Directorate-General for Energy and Climate, responsible for implementing the EU Carbon Border Adjustment Mechanism (CBAM) in France, is currently sending reminder letters to affected importers who have not submitted their declarations. The deadline specified in this letter is generally two months. Missing this window means risking a financial penalty and, from 2026, a complete ban on importing products covered by this regulation. Keewe supports you from A to Z to avoid penalties and save time.
Why did I receive a letter from the DGEC?
The letter indicating a discrepancy with Regulation (EU) 2023/956 (CBAM Regulation), which has notably been sent since April 2025 officially reminds that:
• all tasks related to the transitional period (2023-2025) must be completed via the transitional CBAM registry,
• those related to the effective period (from 2026) must now be processed in the CBAM 2.0 registry (or “definitive”), under EORI SIREN, and
• late importers have a short period to regularize their situation (douane.gouv.fr).
In plain terms: if you have imported CBAM goods since October 2023 without submitting your quarterly reports, authorities are requiring you to do so within 60 days.
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Does this apply to me?
You are if:
- You import products related to the following sectors: steel, aluminum, fertilizers, cement, hydrogen, or electricity (check if your imports are affected using our CBAM checker).
- Your cumulative imports exceed (or will exceed) 50 tonnes per year – a new threshold proposed by the Omnibus Package (Omnibus - douane.gouv).
- You do not yet have the status of “Authorized CBAM Declarant”, which is mandatory to continue importing from January 1, 2026, and which you can apply for via the definitive CBAM registry (or “CBAM registry 2.0”) (taxation-customs.ec.europa.eu).
What is the difference between the transitional period and the effective application period of the CBAM?
The transitional period extends from late 2023 to late 2025 and aims to prepare all stakeholders (European importers, non-EU suppliers, etc.) for the definitive implementation of the CBAM from 2026. During this period, European companies subject to the CBAM must quarterly declare the carbon emissions of imported products on a dedicated online portal (the transitional CBAM registry).
From 2026, with the start of the effective CBAM application period, CBAM declarations will have to be submitted on the definitive registry (or CBAM 2.0 registry), to be clearly distinguished from the transitional CBAM registry. Furthermore, it is through this definitive registry that importers will, as early as March 2025, have to apply for the status of "authorised CBAM declarant," which is essential to continue importing products from 2026.
Penalties: costs add up quickly
- Transitional period (until late 2025) :
- €10 to €50 per tonne of CO₂e undeclared or under-declared.
- Suspension of the processing of your application for the status of "authorised CBAM declarant".
- Definitive period (from 2026) :
- Imports are not possible without obtaining the status of an “authorized CBAM declarant”.
- Payment for certificates + additional penalties as stipulated in the implementing regulation 2025/486.
Omnibus simplification: key takeaways
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Checklist: “48 hours to comply”
- Identify your CN codes and 2023-2024 volumes (export an extract from DELTA I/E).
- Obtain an EORI SIREN number if you don't have one.
- PAE form for account opening CBAM 2.0 (Annex 1 of the DGDDI note) (douane.gouv.fr).
- EU Login + internal/external delegation.
- Consolidate emissions data (direct and indirect).
- Submit the Quarter(x) report (XML format or manual interface).
- Retain audit evidence (future COFRAC verifications).
Keewe automates steps 3→6, leveraging its customs expertise and mastery of carbon calculation methods.
Frequently Asked Questions
What format should the report be in?
XML document according to the official format requested by the European Commission, or manual entry if < 20 lines of data (legifrance.gouv.fr).
Can I still use default values?
No, they have not been accepted since Q3 2024.
What if my suppliers refuse to provide their data?
Document "due diligence"; without proof of effort, the penalty will apply (natlawreview.com).
Ready to secure your imports?
Book a 30-min flash CBAM audit with our experts on the Keewe platform.
Everything you need to know to comply with CBAM before the deadline, avoid a €50/tonne fine, and turn the obligation into a strategic advantage.
The Directorate-General for Energy and Climate, responsible for implementing the EU Carbon Border Adjustment Mechanism (CBAM) in France, is currently sending reminder letters to affected importers who have not submitted their declarations. The deadline specified in this letter is generally two months. Missing this window means risking a financial penalty and, from 2026, a complete ban on importing products covered by this regulation. Keewe supports you from A to Z to avoid penalties and save time.
Why did I receive a letter from the DGEC?
The letter indicating a discrepancy with Regulation (EU) 2023/956 (CBAM Regulation), which has notably been sent since April 2025 officially reminds that:
• all tasks related to the transitional period (2023-2025) must be completed via the transitional CBAM registry,
• those related to the effective period (from 2026) must now be processed in the CBAM 2.0 registry (or “definitive”), under EORI SIREN, and
• late importers have a short period to regularize their situation (douane.gouv.fr).
In plain terms: if you have imported CBAM goods since October 2023 without submitting your quarterly reports, authorities are requiring you to do so within 60 days.
Does this apply to me?
You are if:
- You import products related to the following sectors: steel, aluminum, fertilizers, cement, hydrogen, or electricity (check if your imports are affected using our CBAM checker).
- Your cumulative imports exceed (or will exceed) 50 tonnes per year – a new threshold proposed by the Omnibus Package (Omnibus - douane.gouv).
- You do not yet have the status of “Authorized CBAM Declarant”, which is mandatory to continue importing from January 1, 2026, and which you can apply for via the definitive CBAM registry (or “CBAM registry 2.0”) (taxation-customs.ec.europa.eu).
What is the difference between the transitional period and the effective application period of the CBAM?
The transitional period extends from late 2023 to late 2025 and aims to prepare all stakeholders (European importers, non-EU suppliers, etc.) for the definitive implementation of the CBAM from 2026. During this period, European companies subject to the CBAM must quarterly declare the carbon emissions of imported products on a dedicated online portal (the transitional CBAM registry).
From 2026, with the start of the effective CBAM application period, CBAM declarations will have to be submitted on the definitive registry (or CBAM 2.0 registry), to be clearly distinguished from the transitional CBAM registry. Furthermore, it is through this definitive registry that importers will, as early as March 2025, have to apply for the status of "authorised CBAM declarant," which is essential to continue importing products from 2026.
Penalties: costs add up quickly
- Transitional period (until late 2025) :
- €10 to €50 per tonne of CO₂e undeclared or under-declared.
- Suspension of the processing of your application for the status of "authorised CBAM declarant".
- Definitive period (from 2026) :
- Imports are not possible without obtaining the status of an “authorized CBAM declarant”.
- Payment for certificates + additional penalties as stipulated in the implementing regulation 2025/486.
Omnibus simplification: key takeaways
Checklist: “48 hours to comply”
- Identify your CN codes and 2023-2024 volumes (export an extract from DELTA I/E).
- Obtain an EORI SIREN number if you don't have one.
- PAE form for account opening CBAM 2.0 (Annex 1 of the DGDDI note) (douane.gouv.fr).
- EU Login + internal/external delegation.
- Consolidate emissions data (direct and indirect).
- Submit the Quarter(x) report (XML format or manual interface).
- Retain audit evidence (future COFRAC verifications).
Keewe automates steps 3→6, leveraging its customs expertise and mastery of carbon calculation methods.
Frequently Asked Questions
What format should the report be in?
XML document according to the official format requested by the European Commission, or manual entry if < 20 lines of data (legifrance.gouv.fr).
Can I still use default values?
No, they have not been accepted since Q3 2024.
What if my suppliers refuse to provide their data?
Document "due diligence"; without proof of effort, the penalty will apply (natlawreview.com).
Ready to secure your imports?
Book a 30-min flash CBAM audit with our experts on the Keewe platform.
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