How the CBAM Declaration Works, and What Exporters Must Provide

Updated 2026-10-11.

Exporters do not file CBAM declarations. The EU importer, as an authorised CBAM declarant, files one annual declaration by 30 September for the previous year's imports; the first, for 2026, is due by 30 September 2027. Your job is to give that importer verified emissions data per product, early enough to use it.

At a glance

Date	What happens	Who
1 January 2026	Definitive period starts	EU importers
31 March 2026	Applications submitted by this date allow imports to continue while pending	EU importers
1 February 2027	CBAM certificates go on sale	EU importers
From 2027, each quarter end	Hold certificates for at least 50% of embedded emissions imported so far that year	EU importers
30 September 2027	First annual declaration, covering 2026	EU importers
Ongoing	Supply emissions data per installation and product	Non-EU producers

What goes into the annual declaration

Total quantity of each CBAM good imported in the year.
Total embedded emissions, from verified actual data or default values.
The number of certificates to surrender, after the free-allocation adjustment.
Any carbon price effectively paid in a third country, with evidence.
Verification reports where actual data is used.

What the exporter provides

Data	Detail
Installation	Name, location, identifier and production route
Product	CN code and quantity per shipment or period
Direct emissions	Fuel combustion and process emissions per tonne
Indirect emissions	Electricity consumed (counted for cement and fertilisers)
Precursors	Embedded emissions of bought-in intermediate goods
Carbon price paid	Amount, legal basis and proof, if any
Verification	Statement from an accredited verifier

Worked example: a quarterly data pack

A small Indian steel unit sends 300 tonnes of hot-rolled coil to one EU buyer in Q2 2026.

Field	Value
CN code	7208 (hot-rolled flat products)
Quantity	300 tonnes
Direct emissions intensity	2.0 tCO2 per tonne (from 12 months of fuel and process records)
Embedded emissions	600 tCO2
Verification	Planned before 30 September 2027

The buyer adds this to its year total. If the unit sends nothing, the buyer applies the default value plus its 10% mark-up. Estimate the money at stake in the CBAM cost calculator.

Common mistakes

Sending company-wide emissions instead of installation and product-level figures.
Leaving out precursors such as purchased pig iron or ammonia.
Sharing data after the buyer has already budgeted on default values.
Assuming CBAM covers a product (such as textiles) that it does not.

Frequently asked questions

Do I need to register in the CBAM Registry as an exporter?

No. Producers outside the EU can register installation data so declarants can reference it, but the declaration duty sits with the importer.

What if my buyer imports less than 50 tonnes a year?

An importer bringing in 50 tonnes or less of covered goods in a year (excluding electricity and hydrogen) is exempt, so it may not need your data at all.

How often should I send data?

Agree it with each buyer. Many ask quarterly so they can meet the 50% quarterly certificate holding from 2027 and file the annual declaration on time.

Is the old quarterly CBAM report still required?

No. Quarterly reports belonged to the transitional period, which ended on 31 December 2025.