The CBAM Timeline: Who Must Do What, and When?

The most misunderstood thing about the EU Carbon Border Adjustment Mechanism is not the mechanism — it is the timeline. The definitive period began in 2026, but the first declaration falls in 2027; the obligation sits with the importer, but the data comes from the producer; there is an exemption, but it does not apply to two sectors. This article reduces who-must-do-what-when to one table, based on the European Commission’s own sources.

One ground rule first: every date and percentage here comes from the Commission’s CBAM Q&A and official pages. We have written nothing we could not verify, and we have deliberately left out items — such as penalty amounts — that require a separate reading of the legislation.

The obligation sits with the importer — the data sits with you

The legal chain is built on the EU importer. They buy the certificates, they file the declaration, they face the penalties. As a non-EU producer, no CBAM account is opened in your name.

In practice, though, the weight lands on the producer: your importer can only declare with your product’s embedded emissions data, and that data comes out of your installation. Where a producer cannot supply it, default values apply — and default values come with a mark-up that grows year on year. Knowing the timeline is the exporter’s business as much as the importer’s.

The definitive-period timeline

The 50-tonne exemption: who it saves, and who it doesn’t

The mass threshold introduced by the 2025 simplification package works like this: an importer bringing in less than 50 tonnes of CBAM goods per year needs no authorisation. Two details matter:

• Hydrogen and electricity sit outside the exemption. For those two categories the obligation applies regardless of quantity.
• The threshold works per importer, by mass — not per product. It relieves importers of samples and low-volume shipments; it does not cover anyone trading regularly.

Read from the exporter’s side: if your EU customer imports more than 50 tonnes a year — which describes virtually every ongoing supply relationship — they will ask you for emissions data. A producer who postpones data preparation on the strength of this exemption gets caught unprepared at the first serious order.

The certificate price: the live end of the cost

The certificate price is not fixed; it tracks the EU ETS. The first two quarters of 2026 were published at €75.36 and €75.28 per tCO₂e. Rough scale: a product with embedded emissions of 1 tCO₂e per tonne carries a certificate cost of about €75 per tonne at the current price — €150 at 2 tCO₂e.

Which is exactly why verified actual data pays: default values are set conservatively and carry a mark-up that rises each year. If your installation’s real emissions sit below the default, the difference stays in your importer’s pocket on every tonne — and it is your argument at the negotiating table.

The producer’s to-do list

Three things fall to the exporter:

1. Know your embedded emissions. No verified figure yet? Estimate one from your installation data and benchmark it against the default. If the gap is large, investing in actual data pays for itself.
2. Be ready for the data request. Your importer will need your 2026 data for the 30 September 2027 declaration — and the request usually arrives much earlier, at contract time.
3. Prepare for verification. Reporting actual data requires accredited verification. Structuring your installation data the way a verifier will read it is the single biggest time-saver — and it is precisely the work we do: CBAM verification readiness.

Sources: the European Commission’s CBAM Q&A and the official certificate price page; Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2548. This article is for information; always work from the current official texts when preparing a declaration.