CBAM importer checklist

1 · Establish your scope

• Extract the CN codes of your imports from customs declarations and check whether they fall within CBAM scope.
• Work out whether your total annual imports of CBAM goods stay below 50 tonnes — if so, you have no authorisation obligation (hydrogen and electricity excepted).
• For every good in scope, list the country of origin and the supplier installations.

The exemption threshold works per importer and by mass, not per product.

2 · Become an authorised CBAM declarant

• Apply for authorised CBAM declarant status with the competent authority of the member state where you are established (the application runs through the CBAM registry).
• If you work with an indirect customs representative, settle contractually who carries the CBAM obligations.
• Since 1 January 2026, goods in scope can only be imported with this status — the sanction risk of importing without it sits with the importer.

3 · Collect emissions data from your suppliers

• Ask every supplier installation for embedded-emissions data per product — the Commission’s communication template is the standard format for this.
• Encourage suppliers to share data via the operator module (O3CI) of the CBAM registry; one upload can serve all their customers.
• For goods where no data comes, look up now which default value will apply and budget the cost — defaults carry a 10% mark-up in 2026.
• If you will declare with actual data, plan for accredited verification of that data.

4 · Plan certificate purchases

• Estimate the embedded emissions of your imports (tonnes × value) and budget for certificates.
• From 2027, at the end of each quarter (31 March, 30 June, 31 October, 31 December) you must hold certificates covering at least 50% of the embedded emissions of imports since the start of the year — plan cash flow accordingly.
• Note in your calendar that from February 2027 certificates are bought on the common central platform and the price is published weekly.

5 · Prepare the annual declaration

• File your first CBAM declaration — for the 2026 import year — by 30 September 2027 at the latest; thereafter the rule is the same: declare by 30 September of the following year.
• If a carbon price was effectively paid in the country of origin, collect the documentation for an Article 9 deduction — amounts covered by free allocation or refunded do not count.
• Surrender the certificates corresponding to the declared emissions.

6 · Set up your record-keeping

• Keep imports, supplier data, verification reports and certificate transactions in one filing structure.
• Add an emissions-data delivery clause to supplier contracts — moving the data request into the contracting phase prevents the declaration-season scramble.
• Check CN code changes and Commission legislative updates at least twice a year.