The European Commission has published further CBAM implementation material ahead of the first annual compliance deadline, giving EU importers and overseas suppliers a clearer timetable for preparing declarations, emissions calculations and certificate requirements.
The resources, published on 30 September 2026, cover emissions calculations, CBAM declarations, certificates and the CBAM registry. They accompany the Commission’s fourth implementation webinar and set out practical elements of the compliance process leading to 30 September 2027.
The first annual deadline will require importers to submit their CBAM declaration and surrender the corresponding certificates. The associated financial obligations concern covered imports made during 2026, linking procurement decisions made during the current year with the compliance work required in 2027.
Emissions data becomes part of procurement preparation
The Commission material addresses the use of actual and default emissions values, monitoring methodologies and the roles of the different participants in the CBAM compliance chain. It also covers the proposed extension of CBAM to downstream products.
For procurement teams, obtaining usable information from production installations is becoming an important part of preparing emissions calculations. Suppliers need to provide sufficiently detailed product emissions information for importers to use in their compliance processes.
A general corporate sustainability statement does not provide the same level of information as a complete product emissions file. The distinction is relevant where importers need evidence supporting the emissions attributed to individual covered goods.
Customs records need to match emissions calculations
Importers also need to align their customs records with the goods and production installations represented in their CBAM emissions calculations.
Incomplete identification can increase the amount of reconciliation required as import volumes accumulate. Resolving discrepancies after multiple shipments have been recorded can make the underlying compliance work more difficult.
The Commission’s latest publication sets out the timetable towards the 30 September 2027 deadline, while the preparation of supplier evidence remains a key operational requirement for importers dealing with 2026 CBAM-covered imports.
