CBAM (the EU's Carbon Border Adjustment Mechanism, a levy on the carbon emissions embedded in certain imported goods) sets a hard deadline of September 30 each year, starting in 2027 for the 2026 reporting year, for authorized declarants to file a CBAM declaration through the CBAM registry (the joint EU database where declarants submit data and buy certificates) Regulation (EU) 2025/2083. By that date, you must submit your CBAM declaration for 2026 imports and surrender the matching certificates in the registry, as confirmed by the consolidated Regulation (EU) 2023/956. .Regulation (EU) 2025/2083, adopted on 8 October 2025, shifted the original deadline to this date — not 31 August, as some older guidance still claims. If you import CBAM goods into Estonia, Latvia or Lithuania and cross the reporting threshold, this is the date that belongs on your calendar, not the end of August.
Do you need to verify emissions if you use default values?
Well. You can build your declaration either on the European Commission's default values, standardized emissions figures the Commission publishes for each product category, or on the actual emissions reported by your producer. Independent verification, meaning an outside audit that confirms the figures are accurate, is only required when you use actual emissions; default values carry no verification requirement.
Who actually gets audited?
Verification applies to the production facility in the non-EU country where the goods originate, not to your own company's books. The producer calculates the emissions, an accredited verifier checks the figures, and the result lands in the CBAM registry, where you pull it for your own declaration. Accreditation of verifiers is governed by Delegated Regulation (EU) 2025/2551, which applies to emissions generated from 1 January 2026 onwards.
When should your supplier finish verification?
There is no legal deadline for the supplier's report itself. The Commission's guidance on CBAM verification and accreditation notes that verification can't realistically wrap up before January 2027, since it depends on a full year of 2026 data. The same guidance suggests declarants aim to have the report in hand by mid-August 2027 at the latest. That's a practical target for your own internal checks and for buying certificates in time, not a binding deadline, whatever your compliance calendar might say.
When can you start buying CBAM certificates?
Certificates go on sale through the shared central platform starting February 2027. The same year brings the 50% rule into force: by the end of each quarter, you need to hold certificates covering at least 50% of the emissions embedded in the goods you've imported since the start of the year. This runs continuously throughout the year; it isn't something you settle only once, at the September filing point.
Does the 50-tonne threshold mean this doesn't apply to you?
The threshold is cumulative: 50,000 kg of net weight per year, added up across all CBAM goods together, cement, steel, aluminum and fertilizers combined, not per product. Regulation (EU) 2025/2083 states that once you cross that line, the obligations cover your entire year's imports, not just the portion above the threshold. Electricity and hydrogen aren't subject to this threshold at all, as confirmed by the Estonian Tax and Customs Board.
FAQ
Is the 2027 CBAM declaration deadline August 31?
No. The deadline for filing the CBAM register and declaration is September 30, 2027, not August 31. This applies for the first time in 2027 for the year 2026.
Do you need to verify emissions when using default values?
No. The declaration can be prepared using the European Commission's default values, and verification is not required. Verification is only mandatory for actual emissions.
What does it mean that the production facility is being inspected, not the company?
Verification concerns the production facility in the third country where the goods originate. The manufacturer calculates the emissions, an accredited verifier checks them and the result is entered into the CBAM register.
Does the 50 tonne limit mean that the obligations only apply to the excess?
No. The limit of 50,000 kg net weight per year is cumulative across all CBAM goods and the obligations apply to all imports in the same year. If the limit is exceeded, the impact is not limited to the part in excess.