📦 CBAM definitive regime since January 2026 — first annual declaration due September 30, 2027.  See how it works →
🌍 EU CBAM — Definitive Regime Since January 2026

CBAM: Collect Emissions Data from Suppliers Now.
Annual Declaration Due September 30, 2027.

EU importers of steel, aluminium, cement, fertilizers, electricity, and hydrogen must collect embedded carbon data from non-EU suppliers throughout 2026 — and file their first annual CBAM declaration by September 30, 2027. The data you don't collect today cannot be reported next year.

CBAM Timeline — Where We Are Now

CBAM has two phases. The transitional reporting phase is over. The definitive regime is in effect.

October 2023 – December 2025
Transitional Phase Done
Quarterly CBAM reports submitted via the CBAM Transitional Registry. First embedded carbon data collection cycle. No financial obligations — reporting only to build capacity.
January 2026 – December 2026
Definitive Regime — Act Now Now
CBAM certificates required for imports. Authorized Declarants must collect embedded carbon data from non-EU producers throughout the year. This is the reference period for the first annual declaration.
Every import in 2026 needs emissions data. Collect it now — you cannot reconstruct it retroactively.
3
January 1 – September 30, 2027
First Annual CBAM Declaration
First annual declaration covers goods imported in calendar year 2026. Submitted via the CBAM Registry. CBAM certificates surrendered. Based on verified supplier emissions data collected throughout 2026.
4
From 2028 onwards
Annual Cycle — May 31 Each Year
Annual declaration covers previous calendar year imports. Deadline shifts to May 31. Carbon price aligned with EU ETS. Third-party verifier required for embedded emissions calculations.

What the definitive regime requires

Under EU Regulation 2023/956, authorized CBAM Declarants must report the embedded greenhouse gas emissions of imported goods — tracing emissions back to the production process in the country of origin, not just logistics.

The challenge: your non-EU suppliers must calculate and provide emissions data. Many do not have this capability yet. Starting the collection process in 2026 — not in August 2027 — is the only realistic path to a compliant annual declaration.

6
Covered sectors
Sep 30
First deadline
~€50/t
Est. CO₂ price
CBAM Compliance Status
CBAM Declarant registrationCheck required ⚠
Supplier data requests sent0 sent
Emissions data collected0 responses
Embedded CO₂ calculatedNot started
Annual declaration draftNot started

Which goods are covered by CBAM?

If you import any of these 6 product groups from outside the EU, you are a CBAM Declarant and must collect embedded emissions data.

The list may be extended to additional sectors by 2030 under Article 30 of Regulation 2023/956.
🏗️

Steel & Iron

CN 72 – 73

Pipes, profiles, fasteners, wires, reinforcing bars

🔩

Aluminium

CN 76

Raw aluminium, foil, extrusions, rolled products

🏭

Cement

CN 2523

Portland cement, clinker, hydraulic cements

🌱

Fertilizers

CN 28 – 31

Nitrogen-based: ammonia, nitric acid, urea

Electricity

CN 2716

Imports of electricity from third countries

💧

Hydrogen

CN 2804

Pure hydrogen and hydrogen-derived products

How CBAM Reporter works

Five steps from first import to filed declaration — all within one platform

1

Register your imports

Enter each CBAM-covered import: commodity code (CN), supplier country, quantity, and import date. Link to customs declaration numbers. The system validates against covered goods automatically.

2

Send emissions data requests to suppliers

Auto-generate supplier questionnaires in English aligned with EU Commission guidelines. Track response status per supplier. Send automated reminders. Accept uploaded documentation from each supplier.

3

Calculate embedded carbon

Rule-based engine calculates total embedded greenhouse gas emissions per import line using supplier-provided data or EU Commission default values (flagged for review). Covers direct and indirect emissions per sector methodology.

4

Generate the annual declaration

One-click export of the CBAM annual declaration in the format required by the CBAM Registry (XML/XSD). Includes all mandatory fields: imported quantities, embedded emissions, country of origin, CBAM certificates surrendered.

5

Audit trail & verifier support

Full audit log of all supplier data, calculation methodologies, and declaration versions. Export documentation packages for your accredited verifier. Maintain records for 5 years as required by Article 25.

Key features

📧

Supplier Data Portal

Suppliers fill in their embedded emissions data through a dedicated, no-login portal. Structured data feeds directly into your calculations — no Excel attachments.

🧮

Automated CO₂ Calculation

Rule-based engine applies sector-specific methodologies (Annex III, Implementing Regulation 2023/1773). Default values where supplier data is unavailable — clearly flagged for review.

📤

XML Export for CBAM Registry

Annual declaration exported in the format accepted by the EU CBAM Registry. Validated against the official XSD schema before export — no manual re-entry.

🔔

Deadline Reminders

Automated alerts for upcoming declaration deadlines, supplier response deadlines, and certificate surrender dates. Never miss a regulatory window.

🌍

Multi-Country Supplier Support

Track suppliers across multiple non-EU countries. Country-specific carbon price offsets applied automatically where applicable (Article 9 of Regulation 2023/956).

📊

Carbon Cost Dashboard

Estimate CBAM certificate costs based on current EU ETS price and your embedded emissions. Plan procurement strategy to minimize carbon border exposure.

Pricing

14-day free trial — no credit card required.

Pro
€99
/ year
For multi-entity importers
  • Everything in Compliance
  • Unlimited imports registered
  • Multiple legal entities
  • Custom supplier questionnaires
  • Verifier package + extra audit support
  • Priority support
Choose Pro

Frequently Asked Questions

Who needs to be a CBAM Declarant?

Any EU-based importer (natural or legal person) who imports CBAM-covered goods from non-EU countries must register as an Authorized CBAM Declarant with their national customs authority. The importer bears responsibility — not the freight forwarder or customs broker, unless explicitly authorized. Registration must be completed before importing covered goods under the definitive regime.

What is "embedded emissions" and how is it calculated?

Embedded (or "embodied") greenhouse gas emissions are the CO₂-equivalent emissions released during the production of the imported goods — not shipping. This includes direct emissions (combustion, chemical processes) and, for certain products, indirect emissions (electricity used in production). The calculation methodology is defined in Commission Implementing Regulation 2023/1773, Annex III. Our system applies these rules automatically — with options for actual supplier data or EU default values.

What if my non-EU supplier can't provide emissions data?

You can use EU Commission default values (published per product category and country). However, using defaults generally results in higher CBAM costs, since defaults reflect average or above-average emission intensities. Starting early gives your suppliers time to prepare actual data, which may be significantly lower than defaults. We help you send structured questionnaires so even suppliers with no previous emissions tracking can respond.

Is CBAM different from the EU ETS?

Yes. The EU ETS (Emissions Trading System) covers EU producers who pay for their carbon directly. CBAM ensures that non-EU producers face an equivalent cost when their goods enter the EU. As an importer, you buy CBAM certificates — not ETS allowances — at a price that mirrors the weekly average ETS price. The goal is to prevent carbon leakage (production shifting to countries with lower carbon costs).

When exactly is the first CBAM annual declaration due?

The first annual CBAM declaration covers goods imported during calendar year 2026 (January 1 – December 31, 2026). It must be submitted via the CBAM Registry by September 30, 2027. CBAM certificates must also be surrendered by that date. From 2028 onwards, the deadline shifts to May 31 each year.

Do I need a third-party verifier?

Yes, for the definitive regime. Embedded emissions data used in the annual declaration must be verified by an accredited verifier (Article 8 of Regulation 2023/956). Our platform generates a verifier documentation package — including all supplier data, calculation audit trail, and methodology references — to minimize the cost and time of the verification process.

The data you don't collect in 2026
can't go in your 2027 declaration.

Start your supplier outreach now. Free 14-day trial — set up your first import and send your first supplier questionnaire in under 30 minutes.

Start CBAM Reporter — free →

14-day free trial · No credit card · kontakt@saaslab.one

Application interface: 🇬🇧 English · 🇩🇪 German · 🇵🇱 Polish