CBAM Reporting: Data, Deadlines, Penalties

The EU Carbon Border Adjustment Mechanism (CBAM) introduces mandatory reporting obligations for importers of carbon-intensive goods. Understanding the full scope of CBAM reporting requirements is essential for compliance and cost management.

"CBAM shall apply to imports of goods listed in Annex I, which covers iron and steel, aluminium, cement, fertilisers, electricity, and hydrogen." — EU Regulation 2023/956, Article 2

Which Products Are Covered?

CBAM currently covers six product categories:

Category	CN Code Range	Examples
Iron and Steel	7201–7326	Rebar, sheets, pipes, structures
Aluminium	7601–7616	Ingots, plates, extruded profiles
Cement	2523	Clinker, Portland cement
Fertilisers	2808–3105	Ammonia, urea, nitrate-based
Electricity	2716	Imported electrical power
Hydrogen	2804	Hydrogen, ammonia

If you import any of these into the EU, you must report annually.

What Data Must Be Included in Each Report?

Each CBAM report must contain:

Category	Required Data
Company Information	Name, address, contact details, EORI number, VAT number
Product Information	CN code (8-digit), quantity (tonnes/kWh), country of origin
Emission Data	Direct emissions (tCO₂e), indirect emissions (tCO₂e), emission factor, methodology
Carbon Price	Price paid in country of origin, pricing mechanism type

Calculation Methodology

The default methodology requires using emission factors published in IR (EU) 2025/2621. These factors vary by:

• Product type (CN code)
• Country of origin
• Production method (e.g., blast furnace vs. electric arc for steel)

Actual emission factors can be used if verified by an accredited verifier. This can reduce your reported emissions but requires documented evidence.

Formula

Embedded emissions = Mass of product (tonnes) × Emission factor (tCO₂e/tonne)

Example Calculation

Parameter	Value
Product	Aluminium ingots (CN 7601)
Quantity	50 tonnes
Country	Canada
Direct factor	1.514 tCO₂e/tonne
Indirect factor	0.423 tCO₂e/tonne
Direct emissions	75.7 tCO₂e
Indirect emissions	21.2 tCO₂e
Total embedded	96.9 tCO₂e

Reporting Deadlines

CBAM reports are due one month after each quarter ends. For a full calendar of all important dates, visit our CBAM deadlines page.

Quarter	Reporting Period	Submission Deadline
Q1	January 1 – March 31	April 30
Q2	April 1 – June 30	July 31
Q3	July 1 – September 30	October 31
Q4	October 1 – December 31	January 31

There is no annual report. Each quarter is submitted independently. See our CBAM reporting guide for a step-by-step walkthrough of the process.

Penalties for Non-Compliance

Violation	Penalty
Late submission	€10–€50/tCO₂e
Incorrect data	Correction order + penalty
Repeated non-compliance	Up to €100/tCO₂e
Fraudulent reporting	Full liability + legal action

Who Needs to Register?

Any company that imports CBAM-covered goods into the EU must register with the CBAM Transitional Registry. This applies to:

• Direct importers
• Customs representatives acting on behalf of importers
• Importers using the Simplified CBAM regime (under 100 tonnes/quarter)

Registration requires an EORI number and must be completed before the first report submission.

Documentation Requirements

Maintain the following records for at least 4 years:

• Purchase invoices and shipment documentation
• Emission data from suppliers
• Calculation worksheets
• Submitted reports and confirmation receipts
• Correspondence with national competent authority

CBAM Compliance Checklist

1. Company registered with CBAM Transitional Registry
2. EORI number obtained and verified
3. Product catalogue with correct CN codes
4. Emission factors identified (default or actual)
5. Data collection process established with suppliers
6. Quarterly calculation template ready
7. Report generation tool configured
8. Submission process tested
9. Internal review workflow defined
10. Documentation storage system in place

FAQ

How to comply with CBAM reporting requirements?

Compliance requires five steps: (1) register as a CBAM declarant with your national competent authority, (2) classify all imported products using correct 8-digit CN codes, (3) collect emission data — either default factors from IR (EU) 2025/2621 or verified actual data from suppliers, (4) calculate embedded emissions using the formula: Mass × Emission Factor for both direct and indirect emissions, and (5) submit your declaration by the quarterly deadline. CbamTrack automates steps 2–5 with built-in CN code validation, emission factor database, and one-click report generation.

What documents do I need for CBAM reporting?

You need: (1) proof of company registration and EORI number, (2) customs import declarations for each shipment, (3) supplier emission data or evidence that default factors were applied, (4) carbon price payment receipts if a carbon price was paid in the country of origin, and (5) calculation worksheets showing how embedded emissions were determined. The European Commission provides a Communication Template for installation operators to share data with declarants. Keep all documents for at least 4 years.

Do I need to report if I import through a customs agent? Yes. The responsibility for CBAM reporting ultimately rests with the importer of record.

Can I use estimated emissions? Estimated values are not permitted. You must use either default factors (from IR 2025/2621) or verified actual data.

What if my supplier refuses to provide emission data? Use default emission factors. These are higher than actual values in most cases, which may increase your liability but ensures compliance.

Is there a threshold for CBAM reporting? Yes. Under Regulation (EU) 2025/2083, importers whose total CBAM goods remain below 50 tonnes net mass per calendar year are exempt from CBAM reporting. Above this threshold, all imports must be reported. See our de minimis threshold guide for details.

Does CBAM apply to goods already in transit? Goods imported into the EU from October 1, 2023 onward are subject to CBAM reporting.

Simplify Your CBAM Compliance

Managing CBAM reporting requirements manually is complex and risky. CbamTrack automates the entire process — from CN code classification to emission calculation to multi-format report export. Start with our free CBAM reporting template or explore the best CBAM calculator tools for instant cost estimates.

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Frequently Asked Questions

What is CBAM reporting?

CBAM reporting is the mandatory process where EU importers declare the embedded carbon emissions in imported goods. Under the permanent regime (2026+), importers file annual declarations by September 30 each year, covering all CBAM goods imported in the previous calendar year.

How do I report emissions under CBAM?

To report CBAM emissions: (1) collect embedded emissions data from suppliers, (2) calculate using IR 2025/2621 factors or verified actual data, (3) log into the EU Transitional Registry, (4) submit your annual declaration with supporting documentation.

What are the CBAM reporting deadlines?

Under the permanent regime, the annual CBAM declaration is due September 30 each year. For 2026 imports, the first declaration is due September 30, 2027. Quarterly data collection helps prepare for annual submission.

What documentation do I need for CBAM reports?

You need: company registration, EORI number, customs import declarations, supplier emission data, carbon price payment receipts (if applicable), and calculation worksheets. Keep all documents for at least 4 years.

Can I use default values for CBAM reporting?

Yes, but default values carry a 10% markup in 2026 (rising to 30% by 2028). Using actual verified emissions data is always cheaper and recommended.

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Sources

• EU Regulation 2023/956 — CBAM main regulation
• IR (EU) 2025/2621 — Default emission values and methodology
• Regulation (EU) 2025/2083 — De minimis threshold rules
• European Commission CBAM page

Last updated: July 2026 | Sources: EU Regulation 2023/956, IR (EU) 2025/2621