Under the definitive CBAM regime, only an authorised CBAM declarant may import CBAM goods above the 50-tonne threshold. Once a year, that declarant files a CBAM declaration in the CBAM Registry and surrenders certificates for the embedded emissions of everything it imported the year before. The first declaration covers 2026 and is due on 30 September 2027.
Who must be an authorised declarant
3 kinds of importer need the status:
- An importer of cement, iron and steel, aluminium or fertilisers above 50 tonnes of those goods in a calendar year.
- Every importer of electricity or hydrogen, whatever the quantity.
- An indirect customs representative who declares CBAM goods on behalf of an importer, regardless of that importer's volume.
An importer at or below 50 tonnes of the threshold goods needs no authorisation. How the tonnes are counted is in the 50-tonne threshold.
The application
The application goes through the CBAM Registry to the national competent authority of the Member State where the importer is established. In Germany that authority is DEHSt, reached through the customs portal. The applicant shows:
- establishment in that Member State and a valid EORI number,
- no serious or repeated infringement of customs or tax law in the previous 5 years,
- the financial and operational capacity to meet the CBAM obligations.
The authority decides within 120 days for applications filed after 15 June 2025. Importers who applied by 31 March 2026 may keep importing while their application is pending, even above 50 tonnes. Importing above the threshold without having applied is a breach: the simplification regulation sets the penalty at 3 to 5 times the standard €100 per tonne of CO2e.
Contents of the annual declaration
For each calendar year, the declaration reports:
- The quantity of each CBAM good imported, by CN code, in tonnes, or MWh for electricity.
- The embedded emissions of those goods, as default values or as verified actual values per installation.
- The number of certificates to surrender, after the CBAM factor for the year.
- Any carbon price effectively paid in the country of origin, claimed as a reduction under Article 9.
- The verification reports for every actual value used. Default values need no verification.
The calculation behind the certificate count is in how to calculate CBAM cost.
The calendar for 2026 imports
| Date | What happens |
|---|---|
| 1 January 2026 | Definitive regime applies. Imports start to count |
| 31 March 2026 | Last day to apply for authorisation and keep importing while pending |
| 5 October 2026 | Commission publishes the Q3 2026 certificate price |
| 4 January 2027 | Commission publishes the Q4 2026 certificate price |
| 1 February 2027 | Certificate sales open on the common central platform |
| 30 September 2027 | First annual declaration and surrender, for 2026 imports |
From 2027 a second obligation starts. At the end of each quarter, the declarant must hold certificates for at least 50% of the year's embedded emissions. The CBAM calendar carries every date as a subscribable feed.
A worked declaration line
An importer brought in 1,000 tonnes of hot-rolled steel coil, CN 7208 39 00, from India in Q2 2026, with no supplier data. Its declaration line reads:
| Field | Value |
|---|---|
| CN code, origin | 7208 39 00, India |
| Quantity | 1,000 t |
| Emissions source | Default value, route C, 4.28 tCO2e/t |
| Mark-up 2026 | 10%, so 4.708 tCO2e/t |
| Embedded emissions | 4,708 tCO2e |
| CBAM factor 2026 | 2.5% |
| Certificates to surrender | 118 |
| Price, Q2 2026 | €75.28 |
| Cost | €8,883.04 |
With verified actual emissions of 2.2 tCO2e per tonne from the Indian mill, the mark-up drops away. The line needs 55 certificates and costs €4,140.
Preparation for 2027
- Collect every 2026 import line for CBAM codes, with CN code, origin, net mass and date of release, per importer entity.
- Ask the suppliers behind the largest lines for actual emissions and a verification report, before the verifiers' calendars fill for 2027.
- Price 2026 on the published quarterly prices, and set aside the cash for February to September 2027.
- Check the codes after every Commission change. The 31 July 2026 correction moved default rows between code lengths without changing most values.
Sources: Regulation (EU) 2023/956, Articles 5, 6, 17 and 22, as amended by Regulation (EU) 2025/2083. DEHSt, authorisation for the CBAM definitive regime. Figures computed on 16 September 2026 with the CBAM Data engine.