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On 11 July 2023, CONFIAD participated in a public consultation organized by the European Commission concerning its publication of the draft implementing regulation specifying reporting obligations in the transitional period from October 2023 to December 2025.

In view of CONFIAD, the proposed text would place increased burden on customs representatives. Given a short period for a proper preparation, CONFIAD called on the Commission to postpone the reporting obligations for one year, let alone the application of enforcement measures in the mentioned period. It is unfair and unreasonable to place additional burden solely on reporting declarants for fulfilling the CBAM requirements. CBAM compliance is particularly difficult for SMEs, which do not dispose of necessary resources to ensure extensive compliance with the CBAM reporting obligations.