EU CBAM Import Emissions Reporting Obligations — Transition from Quarterly Reporting to Annual Declaration in the Definitive Period
ENFORCEMENT TIMELINE
In force since October 1, 2023 (quarterly reporting obligation during the transitional period); the first annual CBAM declaration under the definitive period is due September 30, 2027 (covering 2026 imports)
Overview
This card focuses on the specific operational practice for the obligation to report embedded greenhouse gas emissions in imported goods under the EU Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956, CBAM, including the simplification amending Regulation (EU) 2025/2083) — covering the quarterly reporting required during the transitional period (October 2023 to December 2025), and the annual CBAM declaration required from the start of the definitive period in January 2026.
During the transitional period, importers of goods covered by CBAM (iron and steel, aluminium, cement, fertilisers, hydrogen, and electricity) were only required to submit quarterly reports on embedded emissions, with no financial obligation attached. From January 1, 2026, the definitive period requires businesses importing more than 50 tonnes of CBAM goods per year to obtain "authorised CBAM declarant" status; without this status, a business may generally no longer import CBAM goods. The deadline for the annual CBAM declaration (covering total embedded emissions, the number of certificates surrendered, and related data) has been extended from the original May 31 to September 30 under the simplification amendment.
Enforcement Timeline
October 1, 2023: The CBAM transitional period begins. The quarterly embedded-emissions reporting obligation (with no financial burden) takes effect.
December 31, 2025: The transitional period ends.
January 1, 2026: The CBAM definitive period begins. The obligation to obtain authorised CBAM declarant status takes effect (applying to importers exceeding 50 tonnes annually).
March 31, 2026: Businesses that have submitted their authorised CBAM declarant application by this date may continue importing on a provisional basis pending the authorisation decision.
September 30, 2027: Deadline for the first annual CBAM declaration (covering embedded emissions reporting and certificate surrender) for 2026 imports.
Business Impact
Businesses importing CBAM goods need to apply for authorised CBAM declarant status by March 31, 2026, and use the transitional arrangement to maintain continuity of imports while the authorisation is pending. They will need to build a system for collecting actual emissions data (direct/indirect emissions) from overseas suppliers, or determine whether the European Commission's published default values can be applied instead. Where actual measured values are used, third-party verification by an accredited verifier is required.
While the extension of the annual CBAM declaration deadline to September 30 provides more practical breathing room, businesses still need to build out — in parallel with import activity starting in 2026 — the basis for calculating embedded emissions (actual values versus default values), data collection agreements with suppliers, and coordination arrangements with verification bodies. It is also advisable to establish the operational workflow for registering with and uploading data to the CBAM Registry during 2026.