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The CBAM annual declaration: 30 September, and what goes in it

By Jai Nischal Verma · Prices checked 31 Oct 2026 · EU law guide

CBAM Annual Declaration Steps: 30 September, and what goes in it

Law last checked: 31 October 2026. Figures below are copied from the EU texts linked in Sources. This is general information, not legal, tax or customs advice. Rules and prices change; confirm them before you import.

The date to remember is 30 September. Each year, the authorised CBAM declarant files a declaration for the calendar year just finished, and surrenders the matching certificates the same day. The first time that happens is 30 September 2027, for imports made in 2026[3].

The annual CBAM declaration, from the year’s imports to surrender. 1. Close the calendar year: Add up every CBAM good: tonnes, or megawatt-hours for electricity.; 2. Work out embedded emissions: Actual figures need a verifier. Defaults only where the rules allow.; 3. Deduct a carbon price paid abroad: Only a price effectively paid, after rebates, on Article 9's terms.; 4. Apply the free-allocation adjustment: Regulation 2025/2620. For electricity the adjustment is zero.; 5. File and surrender by 30 September: First deadline: 30 September 2027, for goods imported in 2026.The annual CBAM declaration, from the year’s imports to surrender1Close the calendar yearAdd up every CBAM good: tonnes, or megawatt-hours for electricity.2Work out embedded emissionsActual figures need a verifier. Defaults only where the rules allow.3Deduct a carbon price paid abroadOnly a price effectively paid, after rebates, on Article 9's terms.4Apply the free-allocation adjustmentRegulation 2025/2620. For electricity the adjustment is zero.5File and surrender by 30 SeptemberFirst deadline: 30 September 2027, for goods imported in 2026.
The annual CBAM declaration, from the year’s imports to surrender

What you actually file

  1. Close the calendar year. Add up every CBAM good: tonnes, or megawatt-hours for electricity.
  2. Work out embedded emissions. Actual figures need a verifier. Defaults only where the rules allow.
  3. Deduct a carbon price paid abroad. Only a price effectively paid, after rebates, on Article 9's terms.
  4. Apply the free-allocation adjustment. Regulation 2025/2620. For electricity the adjustment is zero.
  5. File and surrender by 30 September. First deadline: 30 September 2027, for goods imported in 2026.

Article 6 says the declaration includes the quantity of each good (megawatt-hours for electricity, tonnes for everything else), and that quantity includes goods that sat under the 50-tonne threshold. It includes the embedded emissions per unit. It includes the number of certificates to surrender, after two reductions: a carbon price effectively paid in a third country, and the free-allocation adjustment. Where you used actual emissions, you attach the verifier’s report[3].

Article 22 is the surrender. The certificates have to be sitting in the registry account. The Commission then takes them off the account[3].

The quarterly holding rule, from 2027

2026 does not have a “buy as you go” rule, because the shop isn’t open yet. From 2027, at the end of each quarter the account has to hold certificates for at least 50% of the embedded emissions in everything imported since 1 January of that year[3]. The free-allocation adjustment counts in that test. You can measure the emissions with default values (without the mark-up) or, where the goods and origin match last year, with the number of certificates you surrendered last year[3].

You don’t have to hit 50% in the same quarter you cross 50 tonnes. The regulation gives you until the end of the following quarter[3].

What this costs you

Miss the surrender and the competent authority can set the number of certificates you should have surrendered and give you a month to hand them over[3]. Overbuy, and the leftover can be repurchased if you ask by 31 October, at the price you paid, up to the limits in Article 23. Certificates purchased for 2026 and still unsurrendered are cancelled on 1 November 2027, unpaid[3]. On the example shipment the simplified 2026 bill is €370.44 at the Q3 price. That is the sum to have ready, not a sum to leave in the account past November.

The calculator is the simplified version of the certificate line. The declarant guide covers getting the account in the first place. Prices are on the tracker.

Sources

Every dated figure on this page is taken from the EU texts below. Where a shipment example uses 100 tonnes and 1.8 tCO2e per tonne, that pair is an illustration, not a published default. Law last checked 31 October 2026. See our methodology and editorial policy. General information, not legal, tax or customs advice.

  1. [1] European Commission: CBAM definitive regime (from 1 January 2026): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-definitive-regime_en (checked 31 Oct 2026)
  2. [2] European Commission: Price of CBAM certificates (quarterly table): https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/price-cbam-certificates_en (checked 31 Oct 2026)
  3. [3] Regulation (EU) 2023/956, consolidated 20 October 2025 (CBAM Regulation): https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20/eng (checked 31 Oct 2026)
  4. [4] Directive 2003/87/EC, consolidated (EU ETS), Article 10a(1a) CBAM factor: https://eur-lex.europa.eu/eli/dir/2003/87 (checked 31 Oct 2026)
  5. [5] Commission Implementing Regulation (EU) 2025/2548 (certificate price method): https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32025R2548 (checked 31 Oct 2026)
  6. [6] Commission Implementing Regulation (EU) 2025/2620 (free-allocation adjustment): https://eur-lex.europa.eu/eli/reg_impl/2025/2620/oj/eng (checked 31 Oct 2026)
  7. [7] European Commission Guidance No. 4 on the free-allocation adjustment (CBAM factor table, including 2034 at 0%): https://taxation-customs.ec.europa.eu/document/download/3aa2c730-4f1b-4524-8f71-d9cfe4880ac7_en?filename=Guidance+No.+4+-+CBAM+calculation+of+the+free+allocation+adjustment+to+the+number+of+CBAM+certificates+to+be+surrendered.pdf (checked 31 Oct 2026)