What Do I Need To Include In My Carbon Border Adjustment Mechanism (CBAM) Reports?
The first phase of the Carbon Border Adjustment Mechanism (CBAM) comes to an end later this year, with full CBAM measures coming into effect from 2026.
In this article, we explore CBAM reports and what needs to be included, the mistakes we have seen during the transition period, and how you can gain clarity as the full measures approach.
Contents:
- CBAM: An overview
- The details required in CBAM reports
- Common challenges importers face with CBAM reports (and how to fix them)
- Attend CSG’s CBAM Webinar for specialist Insights
CBAM: an overview
The Carbon Border Adjustment Mechanism (CBAM) is a new tax for importers of emission-heavy goods, designed to combat carbon leakage within the EU. When a regulated commodity is imported, CBAM certificates must be purchased to offset emissions.
By introducing the CBAM, the European Union is able to offset embedded carbon emissions on imports to bring foreign goods up to the same regulations that domestic manufacturers have to meet. This prevents companies from simply switching to third-country suppliers to avoid emissions regulations.
Currently, the commodities that will be covered are:
- Cement
- Iron and steel
- Aluminium
- Fertilisers
- Hydrogen
- Electricity
CBAM is currently in its transitional phase, whereby you must submit your CBAM reports every quarter. There is currently no requirement for purchasing CBAM certificates.
From 1st January 2026, the full Carbon Border Adjustment Mechanism will be in effect. Annual declarations will be required, and you must be CBAM-authorised to import the goods or make declarations.
Your first annual declaration is required by 31st May 2027.
What details must be included in my CBAM reports?
Your CBAM report must include the following commodity and emission information:
Table from European Commission
Additionally, the following must be declared on your CBAM report:
- Country of origin
- Production methods
- Identification number of the mill (for metal goods)
- If any carbon price has already been paid in the country of origin
Common Challenges Importers Face with CBAM Reports
After working with traders on their CBAM reports during this transition period, we have seen some common errors and misunderstandings around the process:
Not Knowing Your Obligations
CBAM requirements do not delay import clearance, so it is easy to miss them when they are not causing an urgent problem. Although less common now than at the start of the transition period, there is still some confusion about who is responsible for CBAM obligations.
If you are the importer of record, on the import clearance for the EU border movement, you are the one who has the CBAM obligations. Any further inland procedures or sales do not affect this.
If you are the party who is CBAM-obligated and are unsure on what that means, Customs Support Group has several articles which can help you with this:
And, our customs and trade solutions are here to make your CBAM compliance simpler throughout Europe. Contact us to find out more.
Not Being Able to Collect Shipment Data Effectively
Unfortunately, there isn’t a system at customs that provides details for all of your CBAM-classified goods at once – despite a CBAM clause appearing on your import clearance if it applies.
This means that you are reliant on knowing which shipments need to be counted, and having a system in place to collate that data.
This is a struggle when you are importing a variety of products, use many different forwarding or customs partners, or have a high volume of declarations to check manually.
To avoid this, setup processes to collect data on your products in your ERP systems, or work with your customs partner to ensure that you can get the data you need in a useable format.
At Customs Support Group, we are able to run reports for all of our clients’ shipments with us across Europe – whether it’s for CBAM or general use. Having this kind of data on hand saves valuable time and reduces the risk of inaccuracies from manual calculation.
If you could benefit from industry-leading CustomsTech, contact us to see what it can do for yourself.
Not Knowing How to Gather Emissions Data
Even after collating the shipment data, you may have been confused about how to calculate emissions. This is important because your future CBAM certificates will be purchased to offset the values given here.
It is very difficult to ascertain embedded carbon during the import process. Therefore, this must be done beforehand. We recommend you:
- Work with your suppliers and guide them on what information you need from them.
- Involve your procurement and purchasing departments in discussions on CBAM, ensuring that they know the requirements that suppliers must meet and have these requirements written inside the contracts.
- Double check your customs tariff codes with goods classification experts as mistakes can cause hours of work and serious costs.
As hard as it is, you may need to switch suppliers if you cannot get yours to conform to the requirements. The CBAM initiative is designed to bring emissions into focus and create change, so these situations are expected in the short term.
If you need help with due diligence processes or want to know about customs and procurement, then get in touch with our experts for more information about what we can do for you.
Do You Need to Submit CBAM Reports?
Customs Support is a neutral provider of customs services across the EU, helping businesses like yours navigate the ever-changing landscape that is customs. For guidance in preparing for CBAM-reporting, contact us for more information.
