25 August 2026 – On 24 August, the European Commission published its guidance on CBAM verification. Across 141 pages, it explains how to understand just 40 pages of regulation. The bureaucratic madness surrounding the completely out of control carbon tax is entering its next round.
CBAM: A Question for the European Commission
Have You Lost Your Minds?
On 24 August, the European Commission published its guidance on CBAM verification. 141 pages intended to explain just 40 pages of regulation. Page one already tells you what to make of the guidance: it is not legally binding and does not represent an official position of the Commission. Only the European Court of Justice can provide a binding interpretation.
But anyone who reads the new guidance is still nowhere near finished. It also refers to the ten additional CBAM guidance documents published by the Commission on 14 August. On top of that come further documents that have not even been published yet, as well as several DIN standards that have to be purchased.
Almost 600 Pages to Explain One Regulation
The guidance documents now add up to almost 600 pages. And that does not even include the future guidance documents intended to explain to declarants how to submit CBAM reports in the first place and how to use the CBAM Registry.
600 pages. Anyone who needs that much text to explain their own law obviously has something to hide.
VERIFIERS AND NATIONAL ACCREDITATION BODIES
And all of it is entirely non binding, with the European Court of Justice ultimately retaining the final authority over interpretation.
The Commission Has Lost Control of CBAM
The flood of instructions, documents, notices and templates is therefore a clear indication that the Commission has, as expected, driven its CBAM Regulation into the wall, and that not even the Brussels bureaucrats themselves understand their own rulebook any longer, let alone have the ability to provide legally binding answers about it.
With the completely out of control Packaging and Packaging Waste Regulation (PPWR), the Commission at least had the presence of mind on 12 August to say: please do not apply it for the time being. Naturally, that statement was non binding too. But because the Commission desperately wants the revenue from CBAM, the madness is likely to continue.
“The Place That Sends You Mad”
The Berlaymont building, headquarters of the European Commission in Brussels, once again resembles the “Place That Sends You Mad” from the animated film The Twelve Tasks of Asterix from 1976, with CBAM playing the role of the proverbial Permit A38. To this day, that scene holds up a remarkably clear mirror to the madness of administrative procedures and bureaucracy. Unfortunately, there is nothing funny about it any more.
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