CBAM timeline 2026 and 2027: authorised declarant, annual declaration and certificates

If you import iron and steel, cement, aluminium, fertilisers, electricity or hydrogen, four dates govern your calendar: since 1 January 2026 only an authorised CBAM declarant may import CBAM goods; on 1 February 2027 sales of certificates begin on the EU central platform; the first annual declaration, covering 2026 imports, is due by 30 September 2027; and the corresponding certificates are surrendered on that same date.

The declaration deadline moved: Regulation (EU) 2025/2083 of 8 October 2025 shifted it from 31 May to 30 September. If your internal plan still points at May, it is out of date.

Authorised declarant: no status, no imports

This is the entry condition. Since 1 January 2026, only an authorised CBAM declarant, either the importer or its indirect customs representative, may bring goods covered by the mechanism into the Union. It is not a follow-up formality, it is a prerequisite to clearance.

• Competent authority in Spain: the Ministry for the Ecological Transition, MITECO.
• Where to apply: in the EU CBAM Registry, at cbam.ec.europa.eu/authorised-declarant, with the documentation the application requires.
• Who could keep importing while a decision was pending: importers that filed their application before 31 March 2026 could continue importing above the threshold while their authorisation was being decided. Anyone who missed that date has no such cover.

If you have not applied yet and expect to cross the threshold, the right order is to apply before committing the next order, not after.

The 50-tonne de minimis threshold

Regulation (EU) 2025/2083 replaced the old €150 per consignment threshold with a far more workable mass threshold: 50 tonnes of net mass per year, per importer, aggregated across all Annex I goods.

Three points that cost money when overlooked:

1. It is aggregated, not per product. Forty tonnes of steel plus twenty of aluminium is sixty, and you are over.
2. Electricity and hydrogen sit outside the threshold. They always trigger the obligation, whatever the quantity.
3. There is no retroactive exemption. Once you pass 50 tonnes, the obligation covers the whole calendar year, including imports made before you crossed it. That is why you have to be authorised before crossing, not after.

If you are anywhere near the limit, run a cumulative net-mass counter per EORI, with an alert from 40 tonnes.

Month-by-month timeline

Certificates: when you buy them and at what price

Certificates are sold through a common central platform, not on a secondary market. What matters about the price:

• The price is the weighted average of the auction clearing prices of auctioned EU ETS allowances, under Regulation (EU) 2023/956 and Commission Implementing Regulation (EU) 2025/2548.
• For 2026 the price is quarterly: it is calculated during the first calendar week after each quarter closes. Each quarterly price applies to sales of the certificates covering emissions in goods imported during that quarter.
• From 2027 the price becomes weekly.

Regulation (EU) 2025/2083 also cut the quarterly holding requirement: an authorised declarant must hold in its account, at the end of each quarter, certificates covering at least 50% of the embedded emissions in goods imported since the start of the calendar year. It used to be 80%. Less pressure on cash, but it still needs planning: buy everything in September and you pay September's price.

What the annual declaration contains

The declaration sets out, for each type of good, the total quantity imported in the previous calendar year, in tonnes and, for electricity, in megawatt hours. Alongside that:

• The total embedded emissions of those goods, calculated under article 7 of Regulation (EU) 2023/956 where determined from verified actual emissions.
• The total number of certificates to be surrendered, taking into account reductions for the carbon price effectively paid in the country of origin and adjustments for free allocation under the EU scheme.
• Copies of the verification reports issued by accredited verifiers, where actual emissions are used.

Default values are an alternative, but calculating with verified actual emissions usually works out better when the source installation is efficient. That is an economic decision and it should be made with numbers, not out of convenience.

What to ask your non-EU supplier for

This is the slowest piece of work and the one almost nobody starts early enough. Ask in writing, and per production installation rather than per supplier:

• Installation identification: name, address, coordinates and country.
• Production route used, and the reference period of the data.
• Direct embedded emissions per tonne of product, with the methodology applied.
• Indirect embedded emissions per tonne where the good requires them, with the electricity factor used and its source.
• Emissions of the precursor materials incorporated into the product.
• The carbon price effectively paid in the country of origin for that production, with supporting documentation and any rebates or compensation received.
• The accredited verifier's report, if you intend to declare actual emissions.

A supplier that has never done this takes months to produce it. Put it in the purchase terms rather than in a last-minute email. If you sell into the EU from outside, the exporter's angle is covered in the article on CBAM 2026 for Mexican exporters, and how the mechanism works overall is in the CBAM 2026 guide.

What to do before 2026 ends

Fewer than four months remain to close the first calendar year of the definitive regime. What should be settled before 31 December:

1. Confirm authorised declarant status and, if the authorisation is still pending, check the application was filed in time and answer the competent authority's requests promptly.
2. Close the year's net mass counter per EORI and per commodity code, supported by customs declarations. It is the figure that determines whether you passed the de minimis, and the first one you will be asked for.
3. Reconcile the tariff classification of every imported item against Annex I. Commodity code errors are the most common source of surprises, in both directions.
4. Close the data request to suppliers for the installations that account for most of your volume. Starting in 2027 is starting late.
5. Estimate the number of certificates using the quarterly 2026 prices already published, so next year's budget carries a figure rather than an unknown.

If you also manufacture or process inside the EU, much of the per-installation data CBAM demands is the same data you need for your own product carbon footprint in an industrial company. Worth building once, using the method set out in the guide to what a product carbon footprint is and how it is measured.

Frequently asked questions

When is my first annual CBAM declaration due?

By 30 September 2027, covering imports made in calendar year 2026. Regulation (EU) 2025/2083 moved the deadline from 31 May to 30 September.

Can I buy certificates yet?

No. Sales on the central platform start on 1 February 2027 and cover emissions in goods imported during 2026.

Is the 50-tonne threshold per product or per company?

Per importer and year, aggregating all Annex I goods. Electricity and hydrogen sit outside the threshold and always trigger the obligation.

What happens if I cross the threshold mid-year?

The obligation covers the whole calendar year, with no retroactive exemption for earlier imports. That is why it pays to be authorised before crossing it.

How is the certificate price set?

As the weighted average of the auction clearing prices of auctioned EU ETS allowances. In 2026 it is published quarterly; from 2027, weekly.

Can I use default values instead of supplier data?

Yes, but they tend to be conservative. If your supplier is efficient, declaring verified actual emissions reduces the number of certificates to surrender.

Preparing for CBAM and calculating your product carbon footprints is, at bottom, the same data exercise per installation and per unit produced. Our product carbon footprint solution organises that information so the annual declaration comes out of data you already hold.