The first EU CBAM declaration is due September 30, 2027, covering every tonne of Annex I goods an authorized CBAM declarant imported during calendar year 2026. Seven distinct steps separate a complete declaration from a €100-per-tonne penalty, and each step carries documentation requirements that authorized declarants must begin building now, in April 2026, to meet the deadline. This article explains what the CBAM declaration contains, how to calculate the certificates to surrender, and what happens if the filing is late or incomplete.
Caption: The CBAM declaration covers calendar year 2026 imports and must be submitted through the CBAM Registry by September 30, 2027.
What Is the CBAM Declaration?
The CBAM declaration is the annual report, submitted through the CBAM Registry, in which an authorized CBAM declarant states the total quantity of CBAM goods imported, the total embedded emissions in tonnes of CO₂e, and surrenders the corresponding CBAM certificates to the national competent authority. The legal basis is Article 6 of Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083 (the Omnibus regulation). Only an authorized CBAM declarant, a person established in the EU customs territory and granted authorization under Article 3(15), can submit a CBAM declaration and legally import CBAM goods in the definitive phase.
The declaration is not a transitional quarterly report. The transitional period ended December 31, 2025. From January 1, 2026, the definitive phase applies, and the obligation shifts from quarterly reporting to an annual declaration with certificate surrender. The first CBAM declaration therefore covers the full calendar year 2026, with no intermediate reporting requirement for that year.
The EU CBAM applies to six sectors: iron and steel, cement, aluminium, fertilizers, electricity, and hydrogen. Goods from these sectors are identified by specific CN codes listed in Annex I of Regulation (EU) 2023/956. For a complete explanation of how the mechanism connects to the EU ETS and the certificate system, the EU CBAM guide covers the full regulatory background.
How to File the CBAM Declaration: 7 Steps
Filing the CBAM declaration on time requires seven sequential actions. The steps below follow the order established by the importer compliance workflow under Regulation (EU) 2023/956 and the implementing regulations in force from January 1, 2026. Each step depends on the one before it.
Step 1: Compile Import Data for Calendar Year 2026
The declaration starts with a complete record of every CBAM goods shipment imported in 2026. For each shipment, the authorized CBAM declarant must have recorded four data points at the time of import: the CN code of the product, the net mass in tonnes (or MWh for electricity), the country of origin under EU customs rules (not country of shipment), and the name, postal address, and geographic coordinates of the production installation that produced the goods.
Customs authorities automatically transmit import data to the CBAM Registry under Article 25, providing a baseline record. The declarant must reconcile this customs data with internal procurement records and identify any gaps or misclassifications. Importers who did not track production installation identifiers at the time of shipment face retrospective data collection that frequently proves impossible when non-EU suppliers have multiple production sites.
Step 2: Calculate Embedded Emissions per CN Code
Total embedded emissions across all 2026 imports form the core number of the CBAM declaration. The declaration states specific embedded emissions per tonne of goods (tCO₂e/t) by product type and country of origin, which multiplied by the imported quantity produces the total embedded emissions in tCO₂e.
Two routes exist for this calculation. The first route uses actual specific embedded emissions, obtained from the non-EU production installation and calculated according to Implementing Regulation (EU) 2025/2547. For the sectors where indirect emissions are priced (cement and fertilizers), the specific embedded emissions figure covers both direct process emissions and indirect emissions from electricity consumed in production. For steel, aluminium, electricity, and hydrogen, only direct emissions are priced. The second route uses default values published in Implementing Regulation (EU) 2025/2621, set at country-specific averages with a 10% mark-up in 2026 (rising to 20% in 2027 and 30% from 2028). Using default values does not require third-party verification, but the punitive mark-up makes defaults financially costly for importers with emissions below the country average.
The table below shows reference emission factors and illustrative gross CBAM costs at the current EU ETS price of approximately €70/tCO₂ (late March 2026; market data that fluctuates daily):
| Sector | Production route | Emission factor (tCO₂e/t) | Gross CBAM cost at €70 |
|---|---|---|---|
| Steel | Blast furnace (BF-BOF) | ~2.0 | ~€140/t |
| Steel | Electric arc (EAF scrap) | ~0.5 | ~€35/t |
| Cement | Portland | ~0.83 | ~€58/t |
| Aluminium | Primary (direct only) | ~1.5 | ~€105/t |
| Fertilizers | Urea | ~2.5 | ~€175/t |
| Hydrogen | Grey (SMR) | ~9–12 | ~€630–840/t |
Note: These are gross costs before the SEFA free allocation adjustment. In 2026, the CBAM factor is 2.5% (97.5% of free allocation remains), meaning the net certificate obligation is only 2.5% of the gross figure above. A declarant importing 10,000 tonnes of BF-BOF steel with 2.0 tCO₂/t of embedded emissions faces a net 2026 certificate obligation of 500 certificates (10,000 × 2.0 × 2.5%), valued at approximately €35,000 at €70/tCO₂.
For a full explanation of how embedded emissions are measured and calculated by product type, see the CBAM embedded emissions guide.
Step 3: Commission an Accredited Verifier
All specific embedded emissions submitted using actual values require verification by an accredited third-party verifier before the declaration is filed. The legal basis is Article 8 of Regulation (EU) 2023/956, and the verification standard is Delegated Regulation (EU) 2025/2551. For the first verification period covering 2026 imports, a physical site visit to the non-EU production installation is mandatory. Remote verification is not permitted for the first period.
Verifiers must be accredited under EN ISO/IEC 14065 by a national accreditation body recognized by European Accreditation (EA), and they cannot register in the CBAM Registry until September 1, 2026. The European Accreditation Task Force on CBAM was established only in March 2026. With the declaration deadline 13 months after verifier registration opens, and thousands of non-EU production installations requiring first-time physical verification globally, authorized CBAM declarants should contract verifiers immediately, before registration officially begins, to secure capacity. Verifier fees range from €5,000 to €50,000 per production installation depending on complexity. Declarants sourcing from 20 or more installations in countries such as China, India, Turkey, and Russia may face verification costs of €100,000 to €1 million for the 2026 cycle alone.
Importers who cannot obtain actual emissions data from non-EU producers, or who cannot secure an accredited verifier in time, must fall back to default values. Default values require no verification, but the 10% mark-up in 2026 means the declared emissions are higher than actual emissions in most cases, increasing the certificate surrender obligation accordingly.
Step 4: Purchase CBAM Certificates from February 1, 2027
CBAM certificates are available for purchase from February 1, 2027, via the national competent authority through the Common Central Platform. No secondary market exists: certificates can only be purchased from and sold back to the national competent authority. No exchange trading, no bilateral transfers between declarants.
The certificate price for 2026 imports is the quarterly average of EU ETS auction clearing prices during each quarter of 2026 (Article 22(1a), inserted by Regulation (EU) 2025/2083). This means declarants purchasing in early 2027 know the 2026 quarterly prices before they buy, eliminating uncertainty about the price applicable to historical 2026 import flows. For 2027 imports and beyond, the price becomes the weekly average of EU ETS auction closing prices (Article 22(1)).
For the full mechanics of purchasing, pricing, and managing CBAM certificates, the CBAM certificates page contains the complete certificate lifecycle from purchase through surrender and cancellation.
Step 5: Confirm Quarterly Holding Requirements Were Met Throughout 2027
The declaration covers 2026 imports, but the quarterly holding requirement applies to imports being made during 2027 while certificates are being purchased. At the end of each calendar quarter in 2027, the authorized CBAM declarant must hold certificates equal to at least 50% of cumulative embedded emissions from all 2026 imports declared, adjusted for the SEFA free allocation factor (Article 22(2), as amended by Regulation (EU) 2025/2083).
The quarterly holding requirement is not a retrospective check: the national competent authority sends a formal notice if holdings fall below the threshold at the end of any quarter. A declarant who receives such a notice and does not comply faces additional enforcement action. Buyback provisions allow returning up to 50% of certificates purchased in a given year, at the original purchase price, by October 31 of the surrender year (Article 23, as amended). This protects against over-purchasing if actual import volumes or verified emissions come in below estimates.
Step 6: File the Declaration Through the CBAM Registry by September 30, 2027
The CBAM declaration is submitted electronically through the authorized declarant's account in the CBAM Registry, operated by DG TAXUD and authenticated via the UUM&DS system (the same authentication platform as the EU ETS registry). The declaration must contain the following six elements under Article 6 of Regulation (EU) 2023/956:
The six required elements of the CBAM declaration are listed below.
- Total quantity of CBAM goods imported during calendar year 2026, stated by CN code and country of origin, in tonnes or MWh for electricity
- Total specific embedded emissions per type of goods and country of origin, expressed in tCO₂e per tonne
- Total number of CBAM certificates to be surrendered, after deducting any Article 9 carbon price adjustment and the SEFA free allocation factor
- Carbon price effectively paid in the country of origin, with supporting documentation, if an Article 9 deduction is claimed
- References to verification reports issued by accredited verifiers for each production installation where actual values are used
- Free allocation adjustment calculation under the SEFA methodology, where applicable
The CBAM reporting documentation that supports these six elements (monitoring plans, customs declarations, emissions calculation records, and verifier reports) must be retained until the end of the fourth year following the declaration year under Article 6(6). For the 2027 declaration, this means records must be kept until the end of 2031. For more on the documentation requirements that accompany the declaration, see CBAM reporting.
Step 7: Surrender the Required Certificates Simultaneously
Certificate surrender occurs at the moment of declaration filing, not after. When the authorized CBAM declarant submits the CBAM declaration, the corresponding certificates are transferred from the declarant's registry account to the competent authority and cancelled immediately. No grace period exists after the September 30 deadline.
Certificates not surrendered by September 30 trigger the penalty under Article 26(1): €100 per tonne CO₂e for which certificates were not surrendered. The penalty does not extinguish the obligation. The declarant must still purchase and surrender the missing certificates in addition to paying the €100 penalty, making the effective cost of non-compliance approximately €170/tCO₂e at current EU ETS prices: the €100 penalty plus the market certificate price of approximately €70. Certificates that were purchased but not surrendered, and not bought back by October 31, are cancelled by the registry on November 1 under Article 24(1), with no refund.
Caption: Certificates surrendered at declaration equal verified embedded emissions minus Article 9 deductions; unsurrendered certificates incur a €100/tCO₂e penalty under Article 26(1).
What Qualifies for an Article 9 Deduction?
An Article 9 deduction reduces the number of CBAM certificates an authorized CBAM declarant must surrender, by the proportion of embedded emissions already priced through a legally binding carbon pricing scheme in the country of origin. The CBAM declaration must include supporting documentation showing the carbon price effectively paid per tonne of CO₂e, and the Commission must have recognized the foreign scheme as qualifying.
Three conditions all apply simultaneously for an Article 9 deduction to be valid. The carbon pricing scheme in the country of origin must be legally binding and effectively enforced (voluntary offsets and internal corporate carbon prices are categorically excluded). The price must have been actually paid, meaning gross price reduced by any free allocations, rebates, or state compensation the producer received. The Commission must have published the foreign scheme on its list of recognized schemes (publication expected from 2027).
As of April 2026, 4 potential qualifying countries are under Commission assessment: South Korea (K-ETS, most likely to qualify), the UK (UK ETS), South Africa (Carbon Tax), and Switzerland (ETS linked to EU ETS, effectively pre-exempt under Annex III for most products). Countries whose carbon pricing schemes do not currently qualify include China, India, Russia, and Turkey, meaning EU importers of steel, cement, aluminium, and fertilizers from these origins receive no Article 9 deduction and must surrender the full certificate obligation.
CBAM Declaration Compared to the Transitional Quarterly Report
The CBAM declaration is structurally different from the quarterly reports submitted during the transitional period (October 2023 to December 2025). The table below shows the key differences:
| Dimension | Transitional quarterly report | CBAM declaration (definitive phase) |
|---|---|---|
| Legal basis | Article 35, IR (EU) 2023/1773 | Article 6, Regulation (EU) 2023/956 |
| Period covered | Each calendar quarter | Full calendar year |
| Frequency | 4 reports per year | 1 per year |
| Deadline | End of month following quarter | September 30 of the following year |
| Certificate surrender | Not required | Required at filing |
| Verification required | No | Yes (for actual values) |
| Penalty for non-compliance | €10–50 per tCO₂e | €100 per tCO₂e |
The September 30 deadline is final. The Omnibus regulation, Regulation (EU) 2025/2083, extended the original deadline from May 31 to September 30 to give authorized CBAM declarants additional time to obtain verifier reports. The full legal basis for the deadline, including the Article 6 obligation and its interaction with the Omnibus, is set out in the CBAM regulation guide. No further extension is anticipated.
Who Submits the CBAM Declaration?
Only an authorized CBAM declarant submits the CBAM declaration. Authorization is granted by the national competent authority of the EU member state where the declarant is established. The authorization application deadline was March 31, 2026. Declarants who applied by that date may continue importing provisionally while the competent authority processes the application (maximum 120 days from a complete application under IR 2025/486). Importers who have not applied for authorization face penalties of €300–500 per tonne CO₂e for importing without authorization, which is 3 to 5 times the standard penalty rate. For the full authorization process, the CBAM authorized declarant page covers all application requirements.
Is There a De Minimis Threshold for the CBAM Declaration?
Yes. An importer whose total annual net mass of CBAM goods falls at or below 50 tonnes across all CBAM sectors is exempt from the declaration obligation entirely under Article 2(3a) of Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083. This is the de minimis threshold introduced by the Omnibus simplification. The threshold applies per importer per calendar year and covers aggregate imports across all six sectors combined (except electricity and hydrogen, which have no de minimis threshold regardless of volume).
Can the CBAM Declaration Be Amended After Filing?
The regulation does not provide a standard amendment mechanism after the September 30 deadline. Authorized CBAM declarants who identify errors after submission must contact the national competent authority directly. The competent authority holds inspection and audit powers under Article 15, which include the ability to correct declarations in cases of identified discrepancy. The record-keeping obligation (end of 4th year following declaration year) exists precisely to support post-filing audit and correction by the NCA, not by the declarant unilaterally.
What Happens to Certificates Purchased but Not Surrendered?
Certificates purchased during the year but not surrendered at the September 30 declaration remain in the declarant's CBAM registry account after the filing. The declarant may request a buyback of up to 50% of certificates purchased in that calendar year, at the original purchase price, by October 31 under Article 23 (as amended). Certificates still held after October 31 and not surrendered are cancelled by the registry on November 1 under Article 24(1), with no refund or credit.
Does the CBAM Declaration Cover Indirect Emissions for All Sectors?
No. Only cement and fertilizers include indirect embedded emissions (electricity consumed in production) in the CBAM declaration. For steel, aluminium, electricity, and hydrogen, only direct embedded emissions are priced and declared. This is established by Annex II of Regulation (EU) 2023/956. Importers of cement (Portland, CN code 2523) and fertilizers (urea, CN code 3102 10; ammonium nitrate, CN code 3102 30) must include both direct process emissions and indirect electricity emissions in their reported specific embedded emissions per tonne.
Is the CBAM Declaration the Same as the CBAM Report?
The CBAM report and the CBAM declaration refer to the same annual filing obligation under the definitive phase. During the transitional period (2023–2025), "CBAM report" referred to the quarterly filing under Article 35. From 2026 onward, the annual filing is called the "CBAM declaration" in Article 6 of the regulation, and this is the legally operative term. Both phrases appear in commercial and compliance contexts, but the binding legal instrument is the Article 6 declaration, not the transitional report format.