
CBAM Report Submission: Data to Registry
Key Takeaways
- This guide covers guide reporting requirements based on IR (EU) 2025/2621 and EU Regulation 2023/956
- All emission factors and CN codes referenced are verified against the latest EU implementing regulations
- Practical steps and common mistakes are drawn from hands-on implementation experience with the CbamTrack platform
From the team behind CbamTrack
We built this guide based on hands-on experience implementing CBAM compliance for SME importers. The calculations and workflows described here power our own platform — this is not theory, it's what we ship.
The EU Carbon Border Adjustment Mechanism (CBAM) is now fully operational, and importers across steel, aluminium, cement, fertilisers, electricity, and hydrogen sectors must submit annual declarations. If you are wondering how to submit a CBAM report in 2026, this guide walks through every step — from registration to final submission.
"Each authorised CBAM declarant shall submit a CBAM declaration for the goods imported during the preceding calendar year by 30 September of each year." — EU Regulation 2023/956, Article 6
What Is a CBAM Report?
A CBAM report is an annual declaration of embedded emissions for goods imported into the EU. Each declaration must include:
- Total quantity of imported goods by CN code
- Direct and indirect embedded emissions per tonne
- Country of origin for each product
- Carbon price paid in the country of origin (if any)
Declarations must be submitted by 30 September of the year following the import period. The first CBAM declaration for 2026 imports is due by 30 September 2027.
Step 1: Register Your Company
Before you can submit any CBAM declarations, your company must be registered with the CBAM Registry. National competent authorities in each EU member state manage registrations.
You will need:
- Company registration number (EORI number)
- VAT number
- Contact details of the responsible person (declarant)
- List of CBAM goods you import
With CbamTrack, company registration data is stored once and reused across all annual declarations, saving hours of repetitive data entry.
Step 2: Classify Your Products with Correct CN Codes
Each product imported under CBAM must be classified using the correct CN (Combined Nomenclature) code. There are over 79 CBAM-relevant CN codes covering:
- Steel and iron (7201–7326)
- Aluminium (7601–7616)
- Cement (2523)
- Fertilisers (2808–3105)
- Electricity (2716)
- Hydrogen (2804)
Using the wrong CN code is one of the most common CBAM reporting errors. CbamTrack includes a built-in CN code search and auto-mapping feature to eliminate classification mistakes.
Step 3: Collect Emission Data
For each product, you need two types of emission data:
Direct emissions — CO₂ released during production (fuel combustion, chemical reactions) Indirect emissions — CO₂ from purchased electricity used in production
You can use either:
- Default values — Published in IR (EU) 2025/2621. Simpler but typically higher.
- Actual values — Based on your supplier's verified emission data. More accurate but requires documentation.
CbamTrack's emission factor database includes all 79+ default values with automatic application based on CN code and country of origin.
Step 4: Calculate Embedded Emissions
The calculation formula is:
Embedded emissions (tCO₂e) = Activity Data × Emission Factor
| Parameter | Value |
|---|---|
| Product | Steel rebar (CN 7214) |
| Quantity | 100 tonnes |
| Country | Turkey |
| Default factor | 0.672 tCO₂e/tonne |
| Total embedded emissions | 67.2 tCO₂e |
The CbamTrack calculation engine performs this automatically for all your products, including anomaly detection to flag unusual values before submission.
Step 5: Generate and Review Your Report
Once emission data is entered, generate a draft report. Review:
- Product quantities match shipment records
- CN codes are correct
- Emission factors are appropriate
- Country of origin is accurate
- Total embedded emissions are reasonable
CbamTrack generates your report in seconds, not hours. Review it inline, compare with previous quarters, and make adjustments before finalising.
Step 6: Export and Submit
Download your completed report in one of these formats:
- PDF — For your records and auditor review
- XML — For direct upload to the CBAM Transitional Registry
- XBRL — For advanced regulatory filing
- JSON — For integration with internal systems
Submit the XML file through the CBAM Transitional Registry portal before the deadline.
CBAM Reporting Deadlines for 2026
| Quarter | Period | Submission Deadline |
|---|---|---|
| Q1 | Jan–Mar | April 30, 2026 |
| Q2 | Apr–Jun | July 31, 2026 |
| Q3 | Jul–Sep | October 31, 2026 |
| Q4 | Oct–Dec | January 31, 2027 |
Mark these dates in your compliance calendar. Late submissions trigger automatic penalty calculations using the highest default emission factors, which increase your liability.
Common Mistakes to Avoid
- Incorrect CN codes — Double-check classification against the EU Combined Nomenclature database
- Missing indirect emissions — Remember to include purchased electricity
- Wrong default factors — Use the factors specific to your product and country of origin
- Inconsistent product names — Use the same naming across all quarters for accurate comparisons
CbamTrack's validation engine catches these issues before you submit, reducing audit risk.
FAQ
How do I submit a CBAM report?
Submit in 5 steps: (1) Log into the CBAM Registry with your EORI credentials, (2) Select the reporting period, (3) Enter product data — CN codes, quantities, country of origin, (4) Enter emission data — direct and indirect emissions per product, (5) Upload the XML file or enter data manually, then submit. CbamTrack generates the compliant XML automatically from your product and emission data.
What is the CBAM communication template?
The CBAM Communication Template is an Excel file published by the European Commission for installation operators outside the EU. It allows producers to share their installation and emissions data with CBAM declarants in a standardised format. Declarants can then use this data to populate their CBAM reports. The template is available for download from the European Commission's CBAM website.
Do I need to submit a CBAM report every quarter? No. Under the definitive CBAM regime (2026+), declarations are annual, not quarterly. The deadline is 30 September of the year following the import period. However, certificate purchases follow a quarterly schedule in 2026, moving to weekly pricing from 2027.
What happens if I miss the deadline? Penalties start at €10–€50 per tonne of unreported CO₂ and can reach €100 per tonne for repeated non-compliance.
Can I amend a submitted report? Yes, within two months of the submission deadline. After that, amendments require approval from the national competent authority.
Do small importers need to report? Yes. All importers of CBAM goods must report, regardless of volume. However, the Simplified CBAM regime applies if total embedded emissions are below 100 tonnes per quarter.
Is CBAM reporting the same for all EU countries? The regulation is EU-wide, but each member state has its own national competent authority for registration and enforcement.
Sources
- EU Regulation 2023/956 — CBAM main regulation
- IR (EU) 2025/2621 — Default emission values and methodology
- IR (EU) 2025/2548 — Submission deadlines and transitional rules
- European Commission CBAM page
Last updated: July 2026 | Sources: EU Regulation 2023/956, IR (EU) 2025/2621, European Commission CBAM publications
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This article was researched and written with AI assistance. All factual claims, emission factors, and regulatory references have been verified against official EU sources (EUR-Lex, European Commission CBAM page). Last verified: July 2026.
R. Emrah Gökkaya
I built CbamTrack because I saw SME exporters struggling with spreadsheets and confusing regulations. Every article here reflects what I've learned implementing IR 2025/2621-compliant calculations, integrating live EU ETS pricing, and building the emission factor database that powers our platform.
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