A CBAM declaration is the yearly report in which an authorised CBAM declarant states the CBAM goods it imported the year before, their embedded emissions, and the certificates it surrenders for them. The first one covers 2026 imports and is due on 30 September 2027, filed in the CBAM Registry.
Only an authorised CBAM declarant may import CBAM goods above the 50-tonne threshold, so the status comes before the filing. Below you'll find who needs it, what the declaration holds, and one declaration line priced with the CBAM Data engine.
Who must be an authorised CBAM 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 and files no declaration. How the tonnes are counted is in the 50-tonne threshold.
Applying for CBAM declarant authorisation
You apply through the CBAM Registry to the national competent authority of the Member State where you're 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 CBAM declaration
The declaration reports 5 things for each calendar year:
- 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 free allocation adjustment: the year's CBAM factor times the CBAM benchmark, taken off the embedded emissions.
- 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.
CBAM declaration deadline and the 2026 calendar
The first declaration and surrender are due on 30 September 2027, for goods imported in 2026. The dates that lead up to it:
| 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 CBAM declaration line
One line of a declaration, for 1,000 tonnes of hot-rolled steel coil, costs €253,919.44 on default values and about €65,117 on verified actual data. The importer brought in the 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 benchmark, route C | 1.37 tCO2e/t |
| Adjustment, 97.5% factor | 1,335.75 tCO2e |
| Subject to CBAM | 3,372.25 tCO2e |
| Certificates to surrender | 3,373 |
| Price, Q2 2026 | €75.28 |
| Cost | €253,919.44 |
With verified actual emissions of 2.2 tCO2e per tonne from the Indian mill, the mark-up drops away. The line needs about 865 certificates and costs about €65,117. That's about a quarter of the default figure, so supplier data is worth asking for on the biggest lines. Run your own codes in the calculator.
How to prepare for the first declaration in 2027
Start with the import data you already hold, then ask suppliers for emissions data on the lines that cost the most:
- 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. Since 1 September 2026, verifiers can get their own access to the CBAM Registry (European Commission, CBAM news).
- 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.
FAQ
When is the first CBAM declaration due?
On 30 September 2027. It covers everything imported in 2026, and the certificates for it are surrendered on the same date.
Who submits the CBAM declaration?
The authorised CBAM declarant: the importer itself, or an indirect customs representative acting for it. An importer at or below 50 tonnes of cement, steel, aluminium and fertilisers files nothing.
Where is the CBAM declaration filed?
In the CBAM Registry, the same system used to apply for declarant authorisation.
Do I need verified emissions to file?
No. Default values need no verification. Actual values do, and each one needs a verification report attached to the declaration.
What happens if I import above 50 tonnes without authorisation?
It's a breach. The penalty is 3 to 5 times the standard €100 per tonne of CO2e, under Regulation (EU) 2025/2083.
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 recomputed on 19 October 2026 with the CBAM Data engine. With actual data the adjustment is built from the process benchmark and each precursor (Implementing Regulation (EU) 2025/2620), so the actual-data figure is an estimate on the default benchmark.