Who must submit a CBAM report?
Each declarant with a reporting obligation who has imported CBAM goods into the EU in a certain quarter of a calendar year submits a CBAM report to the Commission for that respective quarter, providing details on the imported goods during that time.
According to Article 2 of the CBAM Implementing Regulation (EU) 2023/1773, a declarant subject to a reporting obligation may be any of the following persons:
- an importer who lodges a customs declaration in his own name and on his own account for the release of goods for free circulation in terms of customs law
- a person who has been granted an authorisation to lodge a customs declaration pursuant to Article 182(1) of Regulation (EU) No 952/2013 of the European Parliament and of the Council (10) and who declares the import of goods
- an indirect customs representative may submit the customs declaration, as long as the representative is appointed in accordance with Article 18 of Regulation (EU) No 952/2013 and the importer is located outside the Union. Alternatively, if the indirect customs representative has agreed to comply with the reporting obligations in accordance with Article 32 Regulation (EU) 2023/956, they can also fulfil this role
If various stakeholders are involved in the import, it is important that each tonne of imported goods is attributable to just one declarant, i.e. that it is neither declared twice nor excluded from the declaration.
CBAM goods are those goods listed in Annex I CBAM Regulation or in Annex II(2) of Implementing Regulation (EU) 2023/1773 for the reporting obligations applicable during the transitional period. These goods can be identified by their eight-digit CN code.
How often must CBAM reports be submitted?
CBAM reports must be submitted no later than one month after the end of each quarter, i.e. no later than 31/01, 30/04, 31/07 and 31/10 in 2024 and 2025 and 31/01/2026 if CBAM goods were imported in the respective quarter.
| Quarter | Submission due by | Modification possible until |
|---|---|---|
| 2023: October - December | 2024: 31/01/ | 2024: 31/07/ |
| 2024: January - March | 2024: 30/04/ | 2024: 31/07/ |
| 2024: April - June | 2024: 31/07/ | 2024: 30/08/ |
| 2024: July - September | 2024: 31/10/ | 2024: 30/11/ |
| 2024: October - December | 2025: 31/01/ | 2025: 28/02/ |
| 2025: January - March | 2025: 30/04/ | 2025: 31/05/ |
| 2025: April - June | 2025: 31/07/ | 2025: 31/08/ |
| 2025: July - September | 2025: 31/10/ | 2025: 30/11/ |
| 2025: October - December | 2026: 31/01/ | 2026: 28/02/ |
CBAM reports already submitted can still be corrected up to two months after the end of the reporting quarter. For example, this may be the case if more accurate data on associated emissions is available to the importer after the reporting deadline.
In view of the difficulty of setting up a monitoring, reporting and verification systems in good time, Article 9(2) CBAM Implementing Regulation (EU) 2023/1773 allows a longer period for corrections to the first two quarterly reports, namely until the deadline for the third quarterly report (31/07/2024).
The relevance of the release for free circulation, which involves clearance by the customs authorities, lies in determining the point in time when a product was imported.
The CBAM report must contain the following information:
- total quantity of each type of goods, measured in megawatt-hours for electricity and in tonnes for other goods. This should be broken down by the installations producing the goods in the country of origin
- actual total grey emissions (direct and indirect emissions generated during production) in tonnes of CO2eq emissions per megawatt-hour of electricity or, for other goods, in tonnes of CO2eq emissions per tonne of each type of goods
- CO2 price to be paid in a country of origin for the grey emissions associated with the imported goods, taking into account any available export refund or other form of offset
The actual grey emissions (direct and indirect emissions generated during production) are determined in accordance with Annex IV of the CBAM Regulation and Article 4 and Annex III of Implementing Regulation (EU) 2023/1773.
No verification for the time being
CBAM reports need not be verified during the transition period. Incomplete or incorrect reports may nevertheless be subject to a correction procedure.
Declarants subject to a reporting obligation will only have to submit annual CBAM declarations that require verification instead of quarterly CBAM reports after the transitional phase, from 2026 on.
Where/how are CBAM reports submitted?
The CBAM reports must be submitted to the European Commission’s CBAM Transition Registry. Please use the CBAM Portal for Entrepreneurs application for this purpose: you can gain access through the Customs Portal. Further information can be found on the CBAM Transitional Registry site.
Read the article
Transitional registry and CBAM declarant portal
Sectoral information by the EU commission
The European Commission has produced various support materials to help stakeholders prepare for the new reporting obligations from 01/10/2023 during the transition period (01/10/2023 to 31/12/2025).
We try to keep the links up to date. However, as CBAM is still new, there are often changes on the European Commission's website that make the links out of date. In this case, we would be grateful for your comments.
Further information by the Commission
Questions and answers (FAQ) by the Commission
Taxation and Customs Union: Carbon Border Adjustment Mechanism
Taxation and Customs Union: Carbon Border Adjustment Mechanism (CBAM) - Questions and Answers
Delayed submission of a CBAM report
The document ‘Guidance for declarants - Request Delayed Submission’ of the European Commission, which you can find on the Commission's website under ‘Where to report’, describes the relevant steps to use the ‘Request Delayed Submission’ field in the CBAM transitional register and thereby submit a request for delayed submission of your CBAM report.
Please note the following different procedure for using the ‘Request by NCA’ button in the ‘My Quarterly Reports’ application for CBAM filers in Germany:
- You can use this button not only in cases where you are explicitly reminded by DEHSt to submit your CBAM report.
- Please also use this button independently to request a late submission of your CBAM report. To do this, you must enter a reference number.
- You can create the reference number yourself. It is made up of the respective quarter and your EORI number. Example: Q1-2024/EORI number
- It is not necessary to create a new enquiry to DEHSt in the CBAM transitional register.
- After applying for the ‘Request delayed submission’ function, you have 30 days to submit your report.