CBAM 2027: Are You Ready?
- Annkaren Wambui
- 4 days ago
- 8 min read
🔓 EU importers face their first annual CBAM declaration deadline on 30 September 2027. The time to prepare is now.
Summary: CBAM implementation is already underway, and EU importers of covered goods must prepare for their first annual CBAM declaration and certificate surrender by 30 September 2027 for imports made during 2026. Businesses need to understand which imports fall within scope, how embedded emissions will be reported, whether to use Commission default values or actual verified emissions, and how suppliers and accredited verifiers will support the process. Early preparation will be essential to avoid data gaps and compliance problems as the first deadline approaches. |
CBAM 2027: Are You Ready?
CBAM implementation is already underway. For EU importers of goods covered by the Carbon Border Adjustment Mechanism, the first major annual compliance deadline is approaching. By 30 September 2027, authorised CBAM declarants must submit their first annual CBAM declaration covering their imports during 2026 and surrender the corresponding CBAM certificates.
That may sound like a future deadline. But the information required to meet it is being generated now. Importers need to know which goods fall within CBAM scope, understand the emissions associated with their imports and decide how they will obtain the information needed for their declaration.
For businesses using actual emissions data, this will also require coordination with non-EU producers and accredited CBAM verifiers.
The key question is no longer simply: What will CBAM require in 2027?
It is: What should businesses be doing now to prepare?
What Happens on 30 September 2027?
The CBAM definitive regime requires authorised CBAM declarants to submit an annual declaration through the CBAM Registry. The first declaration, due by 30 September 2027, will cover CBAM goods imported during the 2026 calendar year. By the same date, declarants must surrender the corresponding number of CBAM certificates.
The declaration will include information relating to:
the quantity of CBAM goods imported;
the embedded emissions associated with those goods;
the methodology and information used to determine those emissions;
the relevant CBAM certificates to be surrendered; and
where applicable, verified actual emissions data.
This means the 2027 deadline is not an event that businesses can begin preparing for in September 2027. The underlying customs and emissions information relates to imports taking place throughout 2026.
Which Goods Are Covered by CBAM?
CBAM currently covers imports in six key sectors:
iron and steel;
aluminium;
cement;
fertilisers;
electricity; and
hydrogen.
However, businesses should not assume that every product associated with these sectors is automatically covered.
The scope of CBAM is determined by the relevant goods and tariff classifications.
Importers should therefore begin by reviewing:
their imported products;
commodity codes;
countries of origin;
suppliers;
production locations; and
import volumes.
Understanding which imports fall within scope is the starting point for every other CBAM preparation activity.
Default Values or Actual Emissions?
One of the key decisions for CBAM declarants is how embedded emissions will be reported.
The European Commission allows importers to use either:
default values provided by the Commission; or
actual emissions values determined using the applicable CBAM methodology.
This distinction is important because using actual emissions involves significantly greater coordination across the supply chain.
Where actual emissions are used, the producer outside the EU must provide information about the emissions embedded in the goods. Those actual emissions must then be independently verified by an accredited CBAM verifier.
For some businesses, the decision may therefore involve more than simply choosing between two reporting methods.
It may require assessing:
whether suppliers can calculate emissions using the CBAM methodology;
whether the required production and energy data is available;
whether supporting documentation can be retained;
whether an accredited verifier can complete the verification process; and
whether the information can be made available to the EU importer in time.
Why Supplier Engagement Matters
CBAM compliance does not stop with the EU importer.
Much of the information required to report actual embedded emissions originates with the producer outside the EU.
This means importers may need to establish new information flows between:
Non-EU producer → CBAM verifier → EU importer → CBAM declaration
The European Commission explains that non-EU installation operators monitor and calculate embedded emissions, accredited verifiers review the information and supporting evidence, and CBAM declarants can use the resulting verified information when completing their declarations.
For businesses with complex supply chains, this can create practical challenges.
The importer may not directly control:
how emissions data is collected;
whether a producer understands CBAM methodology;
the quality of production records;
the availability of an accredited verifier; or
the timing of the verification process.
That is why supplier engagement should begin well before the declaration deadline.
Verification Is Becoming a Critical Part of CBAM
Where actual emissions are reported, verification plays a central role in supporting the credibility and reliability of the information. Under the CBAM framework, accredited verifiers independently review the monitoring approach, emissions calculations and supporting evidence provided by non-EU installation operators. They then issue verification reports that can support the information used by CBAM declarants.
The European Commission has also been developing the accreditation and Registry access framework for CBAM verifiers. Accredited verifiers can begin accessing the CBAM Registry from 1 September 2026, subject to the applicable registration and access procedures. The Commission expects the first verification reports to be issued from January 2027.
For importers considering the use of actual emissions, this makes 2026 and early 2027 an important preparation period.
What Should EU Importers Be Doing Now?
Businesses should use the current period to build their CBAM preparation process.
1. Identify CBAM Goods
Review imports and determine which goods fall within CBAM scope.
This should include checking the relevant tariff classifications and identifying the suppliers and production locations involved.
2. Map 2026 Imports
The first annual declaration will cover imports made during 2026.
Businesses should therefore ensure they can identify and retain the relevant customs and commercial information relating to those imports.
3. Review Emissions Data
Determine what emissions information is currently available from suppliers and producers.
Businesses should identify gaps between the information currently received and the information required for CBAM compliance.
4. Decide How Emissions Will Be Reported
Assess whether the business expects to use:
Commission default values; or
actual emissions values.
Where actual values are being considered, businesses should begin discussions with producers as early as possible.
5. Engage Producers
Non-EU producers may need time to understand CBAM methodology, establish internal monitoring processes and collect the required information.
Importers should not assume that suppliers are automatically ready to provide CBAM-compliant emissions data.
6. Consider Verification Requirements
Where actual emissions will be used, businesses should understand how and when the relevant emissions information will be independently verified.
7. Connect Customs and Sustainability Teams
CBAM increasingly sits between several business functions.
Customs teams may understand the imported goods and declarations.
Procurement teams manage supplier relationships.
Sustainability and technical teams may understand emissions information.
Finance teams may need to manage the financial implications of CBAM certificates.
Effective preparation requires these functions to work together.
CBAM Certificates Are Part of the Preparation Process
CBAM compliance will also involve financial obligations. EU importers will be required to surrender CBAM certificates corresponding to the embedded emissions declared for their imported goods, subject to the applicable rules and adjustments. The Commission calculates CBAM certificate prices based on EU Emissions Trading System allowance prices.
During 2026, certificate prices are calculated and published quarterly. From 2027, prices move to a weekly calculation and publication approach, while the central purchasing system for CBAM certificates begins from February 2027. Businesses should therefore consider CBAM not only as a reporting issue but also as a potential financial and commercial planning issue.
The cost of compliance may depend on:
the quantity of imported goods;
the embedded emissions associated with those goods;
applicable CBAM rules and adjustments; and
the price of CBAM certificates.
The Risk of Waiting Until 2027
The biggest CBAM compliance risk may be assuming that preparation can begin shortly before the first declaration is due. By September 2027, businesses will need information relating to imports that have already taken place.
If an importer discovers a supplier data problem late in the process, it may be difficult to reconstruct:
production information;
embedded emissions data;
supporting evidence; or
verification documentation.
Early preparation gives businesses more time to identify weaknesses in their information flow and work with suppliers to address them.
A Practical CBAM Readiness Checklist
Before the first annual deadline, businesses should be able to answer:
Scope
Which of our imports fall within CBAM scope?
Are our product classifications accurate?
Data
Do we have the information needed for our 2026 imports?
What emissions information can our suppliers provide?
Reporting
Will we use default values or actual emissions?
If using actual values, is the information prepared according to the relevant methodology?
Verification
Does the actual emissions data require verification?
Has the producer engaged an appropriately accredited verifier?
Internal Processes
Are customs, procurement, sustainability and finance teams aligned?
Who is responsible for managing the CBAM process?
Financial Planning
Have we considered the potential impact of CBAM certificates on imported goods?
Businesses that cannot yet answer these questions should consider that a signal to begin preparing now.
The Key Message for Importers
The first annual CBAM deadline is 30 September 2027.
But CBAM readiness depends on information and decisions being made long before that date. EU importers should already be reviewing their CBAM goods, supplier relationships and emissions information.
For businesses using actual emissions values, the challenge will be even more closely connected to the ability of non-EU producers to provide reliable data and obtain independent verification. CBAM is no longer simply a future regulatory development.
It is now a practical customs, supply-chain and data-management challenge.
The businesses that start preparing early will have more time to identify gaps, engage suppliers and establish reliable processes before the first annual declaration is due.
The deadline is September 2027. The preparation starts now.
Sources
CBAM Definitive Regime European Commission CBAM Definitive Regime
CBAM Legislation and Guidance European Commission CBAM Legislation and Guidance
CBAM Verification of Emissions European Commission CBAM Verification Guidance
CBAM Actual vs Default Values European Commission CBAM Actual vs Default Values
🎥 EU CBAM 2026: 10 New Guidance Documents
In this video, Customs Manager explains ten new European Commission guidance documents published to support businesses with CBAM implementation. The video covers key areas including embedded emissions, CBAM certificates and sector-specific guidance for cement, hydrogen, fertilisers, iron and steel, aluminium and electricity. It provides a practical overview of the areas EU importers and their overseas suppliers should review as they prepare for the definitive CBAM period and the first annual declaration requirements.
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Related Topics
#CBAM #EUCBAM #CBAMCompliance #CarbonBorderAdjustmentMechanism #CustomsCompliance #ImportCompliance #TradeCompliance #InternationalTrade #CarbonReporting #EmbeddedEmissions #EmissionsVerification #SupplyChainCompliance #EUTrade #GlobalTrade #CustomsManager
Author
Ann Karen | Head of Growth
Updated: September 2026
Disclaimer
This article is provided for general informational purposes only and does not constitute legal, customs or tax advice. Businesses should seek professional advice based on their individual trading arrangements and compliance obligations.
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