Does the Carbon Border Adjustment Mechanism (CBAM) apply to goods made in La Réunion, Mayotte or New Caledonia?
Not for La Réunion, Mayotte, Guadeloupe or Martinique: they are part of the European Union (EU) customs territory. Yes for New Caledonia, which is outside it and counts as a third country. The Commission says CBAM covers only goods originating in third countries and imported into the EU customs territory.
The rule in the Commission's words
The Questions and Answers (Q&A) say the CBAM Regulation applies only to CBAM goods originating in third countries and imported into the customs territory of the Union. The territories that make up that customs territory are listed in Article 4 of the Union Customs Code, Regulation (EU) No 952/2013.
Which places are in and which are out
- In the EU customs territory, so CBAM does not apply to goods produced there: La Réunion, Mayotte, Guadeloupe and Martinique. The Q&A calls them the EU's outermost regions.
- Outside it, so third country for CBAM: overseas countries and territories that are not part of the customs territory of the Union. The Q&A gives New Caledonia as the example. Goods originating there have third-country origin, so the CBAM Regulation applies.
What it means if your goods pass through
Our reading, not a sentence from the Q&A: origin and the place of release decide it. A coil of Indian origin has third-country origin wherever it is sold afterwards, so if it is released for free circulation in La Réunion it is being imported into the EU customs territory, which is the event CBAM follows. Goods made in La Réunion are the ones that stay outside the rule. Ask your customs broker how the declaration will read before the first shipment.
What to ask
- Where will customs accept the declaration that releases the goods for free circulation?
- What origin will the declaration show, and what evidence supports it?
- Is the buyer, or its indirect customs representative, an authorised CBAM declarant in that Member State?
What Senseible does here
Senseible does not file customs or CBAM declarations and does not decide origin or who the declarant is. It reads an Indian plant's fuel invoices and electricity bills into dated, fingerprinted installation records, the plant-side data an EU buyer asks for.
- Goods from Norway, Iceland and Switzerland
- Country of origin against country of production
- Check your EU buyer is an authorised declarant
- Senseible for CBAM
Sources: European Commission, CBAM Questions and Answers, last updated 15 October 2026, question 1.8
Last reviewed 2026-11-05. Re-read Q&A 1.8 and Article 4 of the Union Customs Code if the Commission updates the Q&A. The paragraph on goods passing through is our own reading of the rule.