MACF statement

The new MACF regulation requires European importers to declare the carbon emissions of products purchased from outside the European Union (EU).

The aim of this climate standard is to subject imports to carbon pricing equivalent to that imposed on goods produced in the EU. From 2026, importers will in fact have to buy MACF certificates to compensate for the possible difference in carbon pricing between the exporting country and the EU.

To prepare this MACF statement, the importer must collect information from the supplier. In this article, we explain how to do your MACF declaration.

First step, before starting to develop the declaration, it is necessary to check whether the imported products are covered by the regulations. You can do the test thanks to our MACF checker available hither.

How to declare your MACF imports?

Of the 1^Er October 2023 until December 31, 2025, is the transition period of the MACF, which allows European importers and their suppliers to get started before the final implementation of the regulations in 2026. During this transition period, you will be able to file your declaration quarterly by accessing the MACF register through your account on the French customs website (douane.gouv.fr).

What is the MACF register?

The MACF temporary register is the online portal developed by the European Union on which Importers must file their MACF declarations.

For French importers, the MACF register is accessible via login details to the French customs site. The procedure to follow is specified below (you can also find it on the customs website). hither):

• 1^era step: have an account on the site Douane.gouv.fr
• 2^th step: make sure that this Douane.gouv.fr account is certified — if not the case, two options:
  • Ask your “business correspondent” internally to have the account certified
  • Request your Economic Action Center - PAE - to obtain account certification (identify the PAE on which you depend by clicking hither)
• 3^th Step: connect to the European MACF portal and follow the following steps on the home screen to access your space:

How do you fill out your MACF declaration?

To complete your MACF declaration, you must follow several steps:

1. Identify MACF products among imported products

Imports must belong to specific categories of goods in the sectors targeted by the MACF: Iron & Steel, Aluminum, Cement, Fertilizer, Fertilizer, Electricity and Hydrogen. If you want to know if you are affected by the MACF, you can use our MACF checker hither.

2. Collect the data necessary for carbon emissions calculations (e.g.: the production processes applied, the materials used, etc.)

To be able to calculate accurately and rigorously the emissions associated with the production of imports, it is necessary to be aware of a large number of data. For example, it is necessary to know the production processes applied because the associated carbon emissions differ.

Thus, for the production of steel, one can distinguish between blast furnaces (Blast Furnace) and electric ovens (Electric Furnace), whose emissions are significantly different for the same quantity of steel produced.

In addition, we are interested in the materials (precursors) used in the production of a MACF product, in particular to take into account the emissions associated with these precursors. This is a non-exhaustive list that helps to understand the challenges of data collection. Keewe offers its services to help you navigate this new carbon regulation.

3. Calculate direct and indirect carbon emissions

The calculation of emissions must be done by following specific reporting methodologies that you can find on this link: As a reminder, scope 3 (indirect emissions) is partially included in the MACF declaration. Thus, information related to precursors (inputs) should appear in the reporting but no data on the transport (freight) of products to the importer is required.

4. Prepare the MACF declaration in accordance with the format required by the European authorities

After collecting the data and calculating the emissions, the MACF statement must be prepared in a precise format defined by the regulations.

5. File the declaration on the MACF register of the European Union

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Practical questions about the MACF statement

What is the main difficulty in filing a MACF declaration?

To prepare the MACF declaration, the declarant must collect a lot of data and use it, which highlights several challenges:

• The identification and transmission of technical data from suppliers concerning various aspects of their production processes,
• Calculation of direct and indirect emissions using methods accepted by the EU,
• The transmission of all data through the MACF register before the filing deadline (the end of the month following the end of the quarter covered by the declaration — example, the deadline for filing the Q1 2024 declaration (January-February-March) is April 30, 2024).

Preparing the MACF declaration therefore depends on several factors, such as the relationship between importers and suppliers or even the mastery of methods for calculating carbon emissions.

How long does it take to file a MACF declaration?

Estimating the time required to prepare the MACF declaration is difficult, it depends on several criteria, including:

• The number of different MACF products imported,
• the number of suppliers from which MACF products are imported,
• the method chosen for calculating emissions,
• etc.

One of the key success factors is the ability to easily gather data from suppliers, accurate information that not all suppliers are used to sharing.