EU CBAM
What is due, when, for whom
Every dated duty in the definitive regime, read from the acts and cited to the article that sets it. The next one is marked from your own clock.
Who these dates fall on
Every date below is a duty of the authorised CBAM declarant: the EU importer, or the indirect customs representative acting for an importer not established in a Member State. It is the declarant who files the CBAM declaration and surrenders CBAM certificates. A non-EU producer has no date of its own in these acts; it feels each one through what its buyer needs from it beforehand, above all the emissions data the buyer must declare by the September date.
Reg. (EU) 2023/956 Art. 5(1), 5(1a), 5(2), Art. 6(1), Art. 22(1)
The dates, in order
23 dated duties over the first three emissions years, in the order they fall. Two can share a day: the declaration and that quarter's holding check both fall at the end of September.
| Date | What is due |
|---|---|
| 2026 | |
Apply by now to keep importing while you wait If you expect to pass the 50-tonne threshold, apply for authorised CBAM declarant status by 31 March 2026 to go on importing until your competent authority decides. Article: Reg (EU) 2023/956, Art. 17(7a), Art. 5(1b), Art. 25(1), Art. 25a(3), Art. 26(2a); IR (EU) 2025/486, Art. 4(1) | |
| 2027 | |
Certificate sales open From 1 February 2027 your Member State sells CBAM certificates to you on the common central platform. Article: Reg (EU) 2023/956, Art. 20(1) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
CBAM declaration for 2026 due Submit the CBAM declaration for 2026 and surrender the certificates that cover it. Costs money if missedArticle: Reg (EU) 2023/956, Art. 6(1), Art. 22(1), Art. 26(1) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
Last day to request repurchase Ask for certificates you did not need to be repurchased — your Member State buys them back through the common central platform, and only in a year in which you surrendered certificates. Costs money if missedArticle: Reg (EU) 2023/956, Art. 23(1), 23(2), 23(2a) | |
Unused certificates cancelled Certificates bought for 2026 emissions and still unused are cancelled, without compensation. Costs money if missedArticle: Reg (EU) 2023/956, Art. 24(2) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
| 2028 | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
CBAM declaration for 2027 due Submit the CBAM declaration for 2027 and surrender the certificates that cover it. Costs money if missedArticle: Reg (EU) 2023/956, Art. 6(1), Art. 22(1), Art. 26(1) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
Last day to request repurchase Ask for certificates you did not need to be repurchased — your Member State buys them back through the common central platform, and only in a year in which you surrendered certificates. Costs money if missedArticle: Reg (EU) 2023/956, Art. 23(1), 23(2) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
| 2029 | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
CBAM declaration for 2028 due Submit the CBAM declaration for 2028 and surrender the certificates that cover it. Costs money if missedArticle: Reg (EU) 2023/956, Art. 6(1), Art. 22(1), Art. 26(1) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
Last day to request repurchase Ask for certificates you did not need to be repurchased — your Member State buys them back through the common central platform, and only in a year in which you surrendered certificates. Costs money if missedArticle: Reg (EU) 2023/956, Art. 23(1), 23(2) | |
50% certificate holding check Hold enough CBAM certificates to cover at least half the embedded emissions in everything you have imported since 1 January. Costs money if missedArticle: Reg (EU) 2023/956, Art. 22(2), 22(2a); Art. 31 | |
| 2030 | |
Unused certificates cancelled Certificates you bought in 2028 and still hold are cancelled, without compensation. Costs money if missedArticle: Reg (EU) 2023/956, Art. 24(1) | |
| 2031 | |
Unused certificates cancelled Certificates you bought in 2029 and still hold are cancelled, without compensation. Costs money if missedArticle: Reg (EU) 2023/956, Art. 24(1) | |
Dates as the acts set them · not legal or compliance advice
The rules that hold between the dates
These are not dates. They are true all the time, and the first of them decides whether any date above applies to you at all.
The 50-tonne threshold
Stay under 50 tonnes of net mass in a calendar year — counted across every CBAM good you import, not per product — and you are exempt, though you must still declare that exemption in your customs declaration. Cross it and every obligation applies to everything you imported that year, back to 1 January, not just the excess. Electricity and hydrogen sit outside this exemption.
Article: Reg (EU) 2023/956, Art. 2a(1), 2a(2), 2a(4); Annex VII pt 1
When to apply
Apply for authorised declarant status when you expect to pass the threshold — not after you have.
Article: Reg (EU) 2023/956, Art. 5(1b)
If your account is short
If the Commission finds your account short of the holding requirement, you have one month from your authority’s notice to top it up.
Article: Reg (EU) 2023/956, Art. 22(3)
Your declaration stays reviewable
A submitted CBAM declaration can be reviewed into the fourth year after the year it was due. If the review finds you surrendered too few certificates, you have one month from the decision to surrender the rest; any excess you surrendered is repurchased. The acts we hold set out no route for you to amend a submitted declaration yourself; the review is the route the acts describe (our reading).
Article: Reg (EU) 2023/956, Art. 19(2), 19(5), 19(6)
Keep your records
Keep your records and the verifier’s report until the end of the fourth year after the year the declaration was due. Carbon-price documentation runs for the same period.
Article: Reg (EU) 2023/956, Art. 7(6), Art. 9(3)
If you had to give a guarantee
A guarantee is required only if you were not established throughout the two financial years before you applied. It is released after 30 September of the second year in which you have surrendered certificates.
Article: Reg (EU) 2023/956, Art. 17(5), 17(7)
When your authority asks for something
A request for more information during authorisation carries the deadline your authority sets, at most 30 calendar days. If it later reassesses your status, you have 30 calendar days to respond to its conclusions before a revocation procedure begins.
Article: IR (EU) 2025/486, Art. 5(2), Art. 19(2)
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