The CBAM, or Carbon Border Measure, regulation states that each year By September 30 – and for the first time in 2027 for the year 2026 – the authorised declarant must use the CBAM register to submit a CBAM declaration for the previous calendar year (Regulation (EU) 2025/2083). By this date, the authorized declarant must submit the CBAM import declaration for 2026 and surrender the corresponding certificates in the CBAM register. This is provided for in Consolidated Regulation (EU) 2023/956. Regulation (EU) 2025/2083, adopted on October 8, 2025, changed the original deadline to that date, not August 31, as some guidance materials still indicate. If you import CBAM goods into Estonia, Latvia, or Lithuania and exceed the limit, that date should be on your calendar, not the end of August.
Do you need to verify emissions when using default values?
No. The declaration can be made using the European Commission's default values or the manufacturer's actual emissions. Independent verification is only mandatory for actual emissions; no verification required for default values.
Who is actually being checked?
Verification concerns the third country production facility where the goods originate, not your company's accounting. The manufacturer calculates emissions, an accredited verifier checks them and the result is delivered. CBAM register, from which you will take over for this declaration. The accreditation of the verifier is regulated by Delegated Regulation (EU) 2025/2551, which applies to emissions from 1 January 2026.
When should a supplier complete verification?
There is no statutory deadline for the supplier's report. The Commission verification and accreditation guide notes that the verification cannot be completed before January 2027, as the entire 2026 data set is required. The same guide recommends that the declarant would like to receive the report no later than mid-August 2027. This is a practical recommendation for internal control and certificate purchase, not a mandatory deadline.
When can I start purchasing CBAM certificates?
Certificates are sold on a common central platform from February 2027. The 50% rule also applies from the same year: by the end of each quarter, you must have certificates for at least 50% of emissions from goods imported since the beginning of the year. This applies on an ongoing basis, not just when declaring in September.
Does the 50 tonne limit mean it doesn't affect you?
The limit is cumulative: 50,000 kg net weight per year for all CBAM goods (cement, steel, aluminum, fertilizers) combined. Regulation (EU) 2025/2083 stipulates that when the limit is exceeded, the obligations apply to the entire import of the same year, not just the part that exceeds it. The limit does not extend to electricity and hydrogen, as confirmed by 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.