Since January 2026, EU importers surrender CBAM certificates for embedded carbon. The transitional quarterly reports are gone: one annual declaration, first due 30 September 2027. If you cannot supply verified emissions data, punitive default values price you out.
The EU Carbon Border Adjustment Mechanism left its transitional phase behind in January 2026. This is no longer a reporting exercise: money now changes hands. EU importers must purchase and surrender CBAM certificates for every tonne of embedded carbon in covered goods, priced against the EU ETS (around €65 to €80 per tCO₂ in 2026).
Who is covered
• Iron and steel (HS 72–73): semi-finished, flat-rolled, bars, tubes
• Aluminium (HS 7601–7616): unwrought, alloys, profiles
• Cement (HS 2523): Portland, clinker, other hydraulic cements
• Fertilisers (HS 3102–3105): urea, NPK, ammonia (2814)
• Hydrogen (HS 2804.10)
• Electricity (HS 2716)
First, a correction worth having: the definitive phase does not use quarterly reports.
The quarterly reports belonged to the transitional phase, which ended in December 2025. Under the definitive regime your EU buyer submits one annual CBAM declaration. The first one, covering all 2026 imports, is due on 30 September 2027, and they surrender certificates against it on the same date. There is no CBAM reporting deadline in 2026 at all.
There is a quarterly rhythm, but it is a different one. From 2027, an authorised declarant must hold certificates covering at least half the embedded emissions of everything imported since the start of the calendar year, tested at the end of each quarter. That is a cash-flow obligation on your buyer, not a filing deadline, and it does not apply to the 2026 year.
If anyone has told you a CBAM report falls due this October, they are describing a regime that no longer exists.
What your EU buyer must report
For every consignment, their declaration needs the CN code and quantity, the installation where the goods were produced with its ID, direct emissions per tonne, indirect emissions per tonne, and any carbon price already paid in the country of origin. They cannot invent these numbers. They must come from you, the producer.
The default-value trap
If you do not supply verified actual emissions, the EU assigns default values, deliberately set high and benchmarked on the worst-performing producers. An African smelter running on hydropower at 4.0 tCO₂ per tonne can be defaulted to values three or four times higher. At €70 per certificate, that is hundreds of euros per tonne handed away because the paperwork was not ready.
This is why buyers are choosing suppliers by data-readiness. When two quotes are equal, the supplier with verified emissions data wins, because the other one carries an unpriceable CBAM risk.
Why the longer deadline is not a reason to wait
September 2027 sounds distant. It is not, for two reasons. Your buyer's declaration covers imports made in 2026, which means the data they will need is being generated by your plant right now, and emissions you did not measure at the time cannot be reconstructed afterwards. And procurement teams are not waiting for the deadline: they are writing data-readiness into contracts today, because a supplier who cannot produce verified figures becomes their problem in 2027.
What to do, starting this quarter
1. Record monthly: electricity in kWh, fuel by type, process inputs and outputs per production process
2. Get your grid emissions factor from your utility in kg CO₂ per kWh, or meter your own generation
3. Calculate direct and indirect emissions per tonne for each CN code
4. Have the numbers verified, by an accredited verifier or a documented internal methodology your buyer's verifier can audit
5. Send your buyer a complete data pack before they ask: installation ID, emissions per tonne, carbon price paid
TradeVault's CBAM Reports module assembles the declaration data with EU (€ per tCO₂) and UK (£ per tCO₂) estimates, and Share CBAM Data sends your emissions pack to any importer or agent, including official EU registry XML, from one data entry. Enter it once, answer every buyer forever.