5 CBAM Submission Mistakes to Avoid

After analysing thousands of CBAM submissions across EU member states, six errors appear consistently. Here is how to identify and fix each one.

"Incomplete or incorrect CBAM reports may result in correction orders and financial penalties ranging from €10 to €50 per tonne of unreported emissions." — Implementing Regulation (EU) 2023/1773, Article 16(1)-(3)

Error frequency estimates based on CBAM transitional phase reporting analysis. Penalty amounts sourced from Implementing Regulation (EU) 2023/1773, Article 16(1)-(3). Last verified: July 2026.

Error 1: Incorrect CN Code Classification

The problem: Using wrong or outdated CN codes for CBAM-covered products. This is the most common error, affecting an estimated 30% of submissions.

Why it happens: CN codes are updated annually. Importers often use codes from previous years or confuse similar product categories.

How to fix it: Always verify CN codes against the current EU Combined Nomenclature. Pay special attention to:

• 8-digit vs 6-digit codes (CBAM uses 8-digit)
• Product subcategories (e.g., flat-rolled vs long products for steel)
• Annual updates released in October

CbamTrack automatically maps your products to the correct CN codes using its built-in CN code database, updated annually.

Error 2: Miscalculating Indirect Emissions

The problem: Forgetting to include indirect emissions or using incorrect indirect emission factors.

Why it happens: Indirect emissions are calculated separately from direct emissions, and many importers overlook them or apply the wrong factor.

How to fix it: Always calculate both direct and indirect emissions for every product. Use the indirect factors published in IR (EU) 2025/2621, which vary by country and product category.

Error 3: Missing Country of Origin Documentation

The problem: Not maintaining proper documentation for the country of origin of imported goods.

Why it happens: Emission factors vary by country of origin. Without proper documentation, auditors cannot verify that the correct factor was applied.

How to fix it: Maintain a centralised database linking each product import to its country of origin. Store certificates of origin and supplier declarations with your CBAM records.

Error 4: Using Outdated Default Emission Factors

The problem: Applying emission factors from previous years instead of the latest published values.

Why it happens: Default factors are updated annually. Importers often continue using factors from the previous year without realising they have changed.

How to fix it: Check for updated default factors at the beginning of each year. CbamTrack's emission factor database is updated automatically when new factors are published.

Error 5: Inconsistent Product Naming

The problem: Using different names for the same product across different quarters.

Why it happens: Multiple team members enter product data without standardised naming conventions.

How to fix it: Create a standardised product catalogue with consistent naming. Use the same product name in every quarterly report. CbamTrack enforces consistent naming with product name validation.

Error 6: Overlooking the Annex II Indirect Exemption

A less obvious but equally costly error is misapplying the Annex II indirect emission rules. Steel, aluminium, hydrogen, and electricity are Annex II sectors — only direct emissions are chargeable for CBAM certificate purposes. Indirect emissions must still be reported, but they do not affect your certificate cost. We have seen declarants unintentionally overstate their CBAM liability by including indirect emissions in the chargeable total for Annex II goods, resulting in over-purchased certificates and locked-up capital. Cement and fertilisers are not in Annex II, so both direct and indirect emissions are chargeable. Getting this distinction wrong in either direction creates a compliance problem.

Penalty Overview

Violation Type	Penalty Range	Authority
Late submission	€10–€50/tCO₂e	National competent authority
Incorrect data	Correction order + potential penalty	National competent authority
Failure to submit	Enhanced scrutiny + penalties	National competent authority
Fraudulent reporting	Legal action + full penalty	National competent authority

Prevention Checklist

Step	Action
1	Use up-to-date CN codes for every product
2	Calculate both direct and indirect emissions
3	Document country of origin for all imports
4	Verify emission factors annually
5	Standardise product names across your catalogue
6	Review each report before submission
7	Maintain an audit trail of all data sources
8	Use automated validation tools

FAQ

How do I know if my CN code is correct? Cross-reference with the EU TARIC database and check for annual updates. CbamTrack's CN code search includes automatic validation.

Can I correct errors after submission? Yes, within two months of the deadline. Submit an amended report through the CBAM Transitional Registry.

Are there penalties for reporting errors? Penalties apply for incorrect data if discovered during an audit. Correcting errors voluntarily before an audit typically avoids penalties.

Sources

• EU Regulation 2023/956 — CBAM main regulation
• IR (EU) 2025/2621 — Default emission values and methodology
• IR (EU) 2023/1773 — Transitional implementing regulation (superseded)
• European Commission CBAM page

Last updated: July 2026 | Sources: EU Regulation 2023/956, Implementing Regulation (EU) 2023/1773

Catch Errors Before They Cost You

Manual CBAM reporting is prone to the five errors above. CbamTrack's validation engine automatically checks for incorrect codes, missing data, inconsistent naming, and anomalous values before you submit. Compare CbamTrack with ClimEase for a detailed feature breakdown.