The CBAM customs event of release for free circulation, not merely physical shipment into Europe.
Importation is easy to read as a logistics word, but in CBAM it is a customs-procedure event. The trigger is release for free circulation, not merely a logistics milestone such as shipment, arrival, unloading, or delivery.
CBAM Article 3, point 4 defines importation by reference to release for free circulation under Union Customs Code Article 201. This keeps CBAM import logic tied to a customs procedure rather than everyday shipping language.
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism
release for free circulation as provided for in Article 201 of Regulation (EU) No 952/2013;
Reference: Article 3, point 4
Regulation (EU) No 952/2013 laying down the Union Customs Code
Non-Union goods intended to be put on the Union market or intended for private use or consumption within the customs territory of the Union shall be placed under release for free circulation. Release for free circulation shall confer on non-Union goods the customs status of Union goods.
Contextual upstream customs-procedure anchor used by CBAM to define importation through release for free circulation.
Reference: Article 201
Importation means release for free circulation under Article 201 of the Union Customs Code, used by CBAM as the customs-procedure event through which non-Union goods enter the Union market as Union goods.
Implementation records should identify the release-for-free-circulation event, declaration reference, goods, customs declarant, importer or authorised CBAM declarant, date, customs authority, and evidence needed to connect the customs event to CBAM reporting.
Importation is the customs-procedure event that turns movement of goods into a regulatory trigger. Modelling it precisely prevents shipment data, arrival data, and CBAM obligation data from being treated as the same thing.