Time left before the first CBAM declaration
The annual declaration covering everything imported into the EU during 2026 is due on 30 September 2027. It is filed by the authorised declarant, who is the importer, not by you.
What it means for an exporter is simpler and earlier. Your buyer needs verified emissions data from you well before that date, and the further into the year they get without it, the more likely they are to fall back on default values and price the difference into your goods.
Measured from the start of the definitive period, when the obligation attached, to the day the first declaration is due.
The dates that bind
Who each one falls on is marked, because most of them are not yours.
Embedded emissions in covered goods imported from this date carry a certificate obligation. The transitional reporting-only phase is over.
A separate step from accreditation itself. Verifiers must be accredited by a national accreditation body in the EU or EEA before they can verify anything.
Certificates covering 2026 imports go on sale to authorised declarants through a central platform. This is the point at which CBAM starts costing real money.
From 2027, at the end of each quarter an importer must hold certificates covering at least 50 per cent of the embedded emissions in everything imported since 1 January.
The annual CBAM declaration covering 2026 imports is submitted and the certificates are surrendered. Moved here from the original 31 May 2027.
Eight steps, in the order they have to happen
Step two is the one most guides leave out. It is worth doing first, because for some exporters the honest answer is that none of this reaches them.
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1
Identify which of your products are covered
Match what you export to the CN codes in Annex I of the CBAM regulation. Six sectors are in scope: iron and steel, aluminium, cement, fertilisers, hydrogen and electricity.
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2
Check whether the threshold reaches you at all
An importer bringing in under 50 tonnes a year of covered goods has no obligation. Ask your EU customer where they sit before doing anything else.
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3
Identify the installations
Emissions are calculated per installation and per production process, not per company. Work out which plants produce the goods in question.
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4
Collect the emissions data
Fuel and process data, electricity consumption, production quantities, and the measurements behind them, for a full calendar year.
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5
Calculate embedded emissions
Direct emissions attributed to the production process, plus every precursor, on the functional unit the regulation sets for that product.
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6
Prepare the evidence
A verifier will ask for the records behind each number, not the number. Assemble them while the year is still fresh.
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7
Watch verifier accreditation
Verification has to be done by a verifier accredited by a national accreditation body in the EU or EEA. Track when the first accreditations land.
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8
Verify, then hand the data to your importer
The verified figures go to the EU importer, who is the party that files the declaration and surrenders the certificates.
On step seven. No verifier anywhere in the EU held CBAM accreditation when this was last checked, against 24 national accreditation bodies that have agreed to offer it. Anyone offering you CBAM verification today is offering something that does not yet exist. Treat that as a warning sign rather than an opportunity.
Dates verified against source on 16 September 2026. Preparation estimate. Not an official CBAM declaration or verification.
Common questions
Every answer here is one already established elsewhere in this section, with its source.
What actually happens on 30 September 2027?
That is the deadline for the first annual CBAM declaration, covering everything imported into the EU during 2026. It is filed by your EU importer's authorised declarant, not by you, but it is the date their need for your data becomes real rather than theoretical.
Is that the only deadline that matters here?
No. Certificate sales open on 1 February 2027, and from that point your importer must hold certificates covering at least half their year to date emissions at each quarter end. That means they need usable supplier data well before September, not on the day itself.
What happens if I am not ready by then?
Nothing happens to you directly, but your importer's cost goes up. Without your verified figures they fall back to the Commission's default value plus that year's mark-up, which makes your goods more expensive to bring in than a competitor's who did supply real data.