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CBAM: Submitting Your Report

Guidance on how to file your CBAM report with the EU Commission


I Introduction


I.1. Why CBAM?

The EU's Carbon Border Adjustment Mechanism (CBAM) supports its climate objectives of achieving climate neutrality by 2050 and a net reduction of GHG emissions of at least 55% by 2030. The CBAM imposes the same carbon pricing for imported products as facilities within the EU, reducing the risk of "carbon leakage" and encouraging manufacturers in third-world countries to decarbonize.


I.2. What Products?

 The CBAM focuses on embedded greenhouse gas emissions from certain industries, such as iron and steel, cement, fertilisers, aluminium, hydrogen, and electricity.


I.3. The transition period

The transitional period from October 1, 2023, to December 31, 2025 will facilitate a gradual transition for enterprises and public authorities.


II About the CBAM report


II.1. Introduction

Importers are required to report on the amount of their imports and the greenhouse gas (GHG) emissions incurred during manufacturing. The first report has to be submitted by January 31, 2024, even though they are required to gather data for the fourth quarter of 2023. Once you receive the relevant data, you can submit the quarterly CBAM report to the CBAM Transitional Registry.


II.2. When to submit an extension

Reporting Declarants may amend CBAM reports submitted during the first two reporting periods until the third report is due. According to a provision in the proposed rule, reporting declarants may request an extension of these deadlines for amending reports if they have a valid reason. The final regulation clarifies that these petitions will only be considered for a year after the submission of a report.


II.3. Validating the accuracy of your CBAM reports

Reporting Declarants will not be required to have their quarterly CBAM reports independently validated during the transitional period, as stated in the final regulation.


II. 4. What needs to be reported

The CBAM report needs to contain the following:

  1. Total quantity of goods imported during the preceding quarter

  2. Total embedded direct and indirect emissions

  3. The carbon price is due in the country of origin for the embedded emissions.


The draught regulation stipulates that importers must submit CBAM reports including information on the embedded emissions of goods that have undergone inward processing (often raw materials imported for use in the manufacture of other goods) before being approved for free circulation.


II.5. Reporting requirements for the CBAM report

The Implementing Regulation on reporting requirements and methodology provides flexibility when it comes to the values used to calculate embedded emissions on imports during the transitional phase. The transitional registry offers additional simplifications, such as recording emission data for reuse, reconducting previous reports, and reporting data based on an XML file. The European Commission has announced that only the EU method will be accepted for reporting emissions from the CBAM transitional registry starting 1 January 2025. Until the end of 2024, companies will have the choice of reporting in three ways:


  1. full reporting according to the new methodology (EU method)

  2. reporting based on an equivalent method (three options) and

  3. reporting based on default reference values (only until July 2024, i.e for Q4 of 2023 and Q1&Q2 of 2024.


III Introduction to Default Values


According to the Implementing Regulation, Declarants may use default values for reporting embedded emissions of imports covered by the CBAM. However, they are only allowed to be used if there is a dearth of precise data on the embedded emissions of certain items at the installation level.



The following conditions apply in this instance:

  • To calculate embedded emissions to the end of 2024, other methods that are covered by the present carbon pricing programmes, required emission monitoring programmes, or certified emissions monitoring programmes may be employed.

  • Until 31 July 2024, embedded emissions may be calculated using default values made available by the Commission, but only in circumstances where the aforementioned data is not easily accessible.


The Commission has published the default values guidance that can be used to determine embedded emissions in imported goods (except electricity) covered by the CBAM.






III.1 Default Values during the Transition Period

During the transitional CBAM period, declarants can use default values for imported CBAM goods apart from electricity. These values are based on estimations by the European Commission and are weighted by production volumes. They apply independently of the country of origin and only until the end of the transitional period on 31 December 2025. Study the manual below.


III.2. The Default Value Rules For CBAM


Given the above conditions, the default values for CBAM items other than electricity may be utilised to report embedded emissions for the transitional CBAM period ending December 31, 2025. Declarants should use them when they cannot report true emissions. From the first reporting quarter, these default values will be modified regularly to reflect input from non-EU CBAM producers and data from the first reporting period.


A weighted "world" average based on production volumes is shown in the document below. No matter the CBAM items' country of origin, these default values are valid until December 31, 2025, the end of the transitional period. In 2026, new defaults will take effect. A suitably established markup based on each exporting nation's average emission intensity will enhance these results. A 2025 implementation date for the implementing legislation will set default settings.


Download the default values here:




III.3. After the Transition Period

From 2026, another set of default values will apply, set at the average emission intensity of each exporting country, increased by a proportionately designed markup. The default values will be determined through an implementing act planned for adoption in 2025. The default values represent a 'world' average, weighted by production volumes, and are based on publicly available data from the Commission's Joint Research Centre.




IV Filing the CBAM Report


The Commission created the CBAM interim registry in order to assist exporters in fulfilling their CBAM requirements. Access to the registry should be requested from the National Competent Authority (NCA) of the Member State in which the supplier is located.



IV.1. Application User Manual For the CBAM registry


This document aims to guide reporting declarants and CBAM declarants on how to use the CBAM Trader Portal (CBAM Declarant Portal). The target audience includes importers of CBAM goods into the EU, the Project team of the Directorate-General Taxation and Customs Union (DG TAXUD), DG TAXUD-Business Units C.2 and C.5, Directorate General for Informatics (DIGIT), DG CLIMA, EU Member states and their National Competent Authorities, SOFT-DEV Project team, Quality Assurance Contractor, and operational teams. The document is organized into four chapters: Introduction, General Information, Getting Started, Using the System as CBAM Reporting Declarant, and Annex - CBAM Report Structure in XSD format and a sample ZIP. The features described comply with CBAM Release 1.2. The document is organized into four chapters, each providing practical and theoretical details for the topic.


IV.2. XSD File

Reporting declarants may get the complete format of the CBAM quarterly report by using the XSD file and sample ZIP file included in the CBAM Transitional Registry User Manual. Once these files are transferred to the Registry, the data for the quarterly report may be filled in right away. Getting the XSD and sample ZIP files is simple; just click the links below.



IV.3. How to access the transitional registry

Access to the Transitional CBAM registry should be requested through the National Competent Authority (NCA) of the Member State in which the importer is established.



The recording of an info session on the CBAM Transitional Registry can be found here.


More Information & links


Our 2024 Step-By-Step Guide to the EU's Carbon Border Adjustment Mechanism (CBAM)

2024 - the year of CBAM implementation: Discover CBAM why it matters, how it is implemented and what obligations CBAM goods importers and producers need to prepare for. You will also find a step-by-step guide towards CBAM compliance filled with links, guides and more. Read here


CBAM Training


Live Course: CBAM & Practical Implementation in Companies

This course develops the competencies that professionals need to deal with all aspects of CBAM - the EU Carbon Border Adjustment Mechanism, including how to calculate carbon, apply for certificates, and how to set up CBAM conform procedures.


On-Demand Course: CBAM

Our Customs Training Center offers a comprehensive EU's Carbon Border Adjustment Mechanism (CBAM) training program that spans 4 hours - delivered online and pre-recorded so that you can watch it anywhere, anytime, and from any device. Our expert instructor, Arne Mielken, will guide you through the CBAM's intricacies, ensuring you thoroughly understand the process. This course covers the full range of CBAM topics, giving you the knowledge and skills you need to succeed. Whether you're new to CBAM or looking to refresh your existing skills, our Full Training program is the perfect choice. Join us and take your CBAM knowledge to the next level. Buy Now


Webinar: CBAM

Unpacking CBAM is a comprehensive webinar that will provide you with a detailed analysis and contextualisation of the EU's Carbon Border Adjustment Mechanism. This mechanism aims to reduce carbon emissions by importing goods that are produced using environmentally sustainable methods. In this webinar, you will learn about the implementation of CBAM, its impact on international trade, and how businesses can prepare for it. Our expert panelists will unpack the complexities of CBAM and provide you with valuable insights to navigate this new landscape. Don't miss out on this opportunity to stay ahead of the curve.


Get CBAM Support


Support Bundle

Presenting the EU's Carbon Border Adjustment Mechanism (2024 Support Bundle)! Learn how powerful this all-inclusive bundle is and get the capacity to implement CBAM in your company. Take advantage of this chance to remain on top of things and make wise choices. Get the 2024 Support Bundle right now! When you download this package, what will you receive? It is jam-packed with legislation, fact sheets, guidelines, explainers, and webinar slides. Let's examine what is contained below. Do, get compliant with CBAM right away and download the support bundle without delay today.


Free Expert Call

Got a question? Worry or Concern? Don't! Because we are here to help on all matters of customs, export controls, supply chain and cost reduction strategies, border clearance, imports & exports, excise, VAT, veterinary controls and sanctions. Simply book a free-of-charge call and let's talk about it and see what we can do, together! Find a time and date that suits you. Book here.




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