CBAM Annual Declaration Guide (2026)

Under CBAM's permanent regime (2026+), importers file annual declarations (first due September 30, 2027). However, collecting embedded emissions data quarterly is essential for accurate annual reporting. This guide explains the annual declaration process and why quarterly data collection matters.

"The transitional period for CBAM reporting ended on 31 December 2025. From 1 January 2026, importers must submit annual CBAM declarations." — European Commission, CBAM Q&A (May 2026)

Key dates:

• Annual declaration deadline: September 30 each year
• Covers previous calendar year's imports
• Must include all CBAM-covered products

Why Quarterly Data Collection Matters

Annual declarations require aggregated data from the full year. Collecting quarterly ensures:

• Track seasonal variations in production and imports
• Enable timely compliance monitoring
• Align with the EU ETS quarterly compliance cycle
• Allow regular adjustments to emission calculations

Each quarter stands alone — you cannot carry forward excess emissions or under-report from one quarter to another. This is a common misunderstanding that leads to compliance gaps.

How the Annual vs Quarterly Confusion Costs Money

The distinction between quarterly data collection and annual declaration is one of the most misunderstood aspects of CBAM. In 2026, you collect data quarterly, but submit one annual declaration by September 30, 2027. However, certificates are purchased quarterly starting February 2027 — meaning if you wait until September 2027 to calculate your emissions for the first time, you will have no idea how many certificates to buy. This timing mismatch catches many first-time declarants off guard.

CbamTrack addresses this by generating rolling quarterly estimates that feed directly into certificate purchase planning, so you always know your position before each certificate purchase deadline.

Real-World Scenario: Why Quarterly Tracking Saved €47,000

A Turkish steel rebar importer we work with tracks data quarterly through CbamTrack. In Q2 2026, they noticed a sudden spike in embedded emissions from one supplier due to a production method change from EAF to BF-BOF route. Because they caught it within the quarter, they renegotiated the supply contract and saved an estimated €47,000 in potential CBAM certificate costs for the year. Had they waited until the annual declaration deadline, the supplier change would have gone undetected and the higher costs would have been locked in.

Preparing for Each Quarter

Timeline	Tasks
30 days before	Review import data, request supplier emissions, check CN code changes, verify product catalogue
15 days before	Enter emission data, calculate embedded emissions, review for anomalies, generate draft report
Submission day	Finalise report, export XML, save PDF, submit through CBAM Registry

Data You Need Each Quarter

Product Data

• Product name and description
• CN code (8-digit)
• Quantity imported (tonnes or kWh)
• Country of origin
• Production method (if relevant)

Emission Data

• Direct emissions per tonne
• Indirect emissions per tonne
• Emission factor source (default or actual)
• Carbon price paid (if any)

Sample Quarterly Report Data

Product	CN Code	Quantity (t)	Origin	Direct (tCO₂e/t)	Indirect (tCO₂e/t)	Total (tCO₂e)
Steel rebar	721420	120	Turkey	0.535	0.137	80.64
Aluminium ingot	760110	45	Canada	1.514	0.423	87.17
Cement clinker	252310	200	Egypt	0.723	0.089	162.40

CbamTrack's dashboard shows your quarterly data in a similar table, ready for review and export. Try our free CBAM calculator for instant cost estimates, or visit our CBAM reporting software page for a full-featured solution.

Common Quarterly Challenges

Supplier Data Delays

Start requesting data 4–6 weeks before quarter end. Use default factors if supplier data is not available by the deadline.

Product Code Changes

CN codes are updated annually. Always verify you are using the current year's codes. CbamTrack automatically updates its CN code database.

Inconsistent Product Naming

Use standardised product names across all quarters. This enables accurate quarter-over-quarter comparisons and anomaly detection.

Verification and Audit

Each report should be internally verified before submission:

1. Quantity check — Do import quantities match shipment records?
2. Factor check — Are emission factors appropriate for the product and origin country?
3. Completeness check — Are all CBAM-covered products included?
4. Trend check — Are emissions consistent with previous quarters?

CbamTrack's audit trail logs every change and provides a complete revision history for compliance verification.

Sources

• EU Regulation 2023/956 — CBAM main regulation
• IR (EU) 2025/2548 — Annual declaration and transitional rules
• European Commission CBAM page
• CBAM compliance guide — A complete overview of obligations and penalties
• CBAM deadlines calendar — All key dates in one place

FAQ

What if I discover an error after submission? Errors can be corrected within two months of the deadline. Submit an amended report through the registry.

Do I report actual shipments or ordered quantities? Report actual import quantities based on customs declarations for the quarter.

How do I handle returned or rejected goods? Only goods that clear EU customs are reportable. Returned or rejected goods are excluded.

Can I automate my quarterly report generation? Yes. CbamTrack supports scheduled auto-generation of quarterly reports for Professional plan users, with automatic data aggregation and template-based formatting. For a broader view of available tools, explore our CBAM calculator alternatives.