CBAM Reporting Requirements Explained: What EU Importers Must Know

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.

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 quarterly.

What Data Must Be Included in Each Report?

Each CBAM report must contain:

Company Information

• Name, address, contact details of the declarant
• EORI number
• VAT number

Product Information

• CN code (8-digit level)
• Total quantity imported (tonnes or kWh for electricity)
• Country of origin

Emission Data

• Direct embedded emissions (tCO₂e)
• Indirect embedded emissions (tCO₂e)
• Emission factor used (default or actual)
• Methodology for determining actual emissions (if applicable)

Carbon Price Information

• Carbon price paid in the country of origin (if any)
• Type of carbon pricing mechanism (ETS, carbon tax, etc.)

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 significantly but requires documented evidence.

Formula

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

Example Calculation

Importing 50 tonnes of aluminium ingots (CN 7601) from Canada with default emission factor of 1.514 tCO₂e/tonne:

Direct emissions: 50 × 1.514 = 75.7 tCO₂e Indirect emissions: 50 × 0.423 = 21.2 tCO₂e Total: 96.9 tCO₂e

Reporting Deadlines

CBAM reports are due one month after each quarter ends:

• Q1: Due April 30
• Q2: Due July 31
• Q3: Due October 31
• Q4: Due January 31

There is no annual report. Each quarter is submitted independently.

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

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? There is no minimum quantity threshold. All imports of CBAM-covered goods must be reported.

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

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