The first CBAM declaration, due 30 September 2027: what it contains and what you pay

By 30 September 2027, each authorised CBAM declarant submits in the CBAM registry the declaration of what it imported in 2026 and surrenders the corresponding certificates. The declaration states, per type of goods, the tonnes imported (the first 50 included), the embedded emissions, at the default value or the supplier’s verified figure, and the number of certificates, plus the verification report where the figure is verified. A distributor that imported 400 t of welded tube and 250 t of coil from China in 2026 would surrender about 1,530 certificates, about €125,939 at the default value.

Simulate your declaration

What the declaration contains

Article 6(2) of Regulation (EU) 2023/956, as worded by Regulation (EU) 2025/2083, asks for four things:

1. The total quantity of each type of goods imported in the preceding year, in tonnes.
2. The total embedded emissions in those goods, in tonnes of CO₂e per tonne, calculated with the method of Annex IV and, if actual, verified.
3. The number of certificates to surrender: those emissions minus the free-allocation adjustment of Article 31 and, where applicable, the reduction for a carbon price paid outside the EU (Article 9).
4. Copies of the verification reports, where actual emissions are declared.

It is submitted in the CBAM registry. An implementing act sets the format, with the detail per installation, country of origin and type of goods behind the totals.

Every tonne counts, the first 50 included

The 50 t threshold decides who is exempt; it is not a free 50 t. Once you are an authorised declarant, the declaration covers the total quantity imported in the year, “including the imported goods below the single mass-based threshold” (Article 6(2)(a)). If you imported 60 t, you declare and pay for 60 t. Who needs the status and how to apply is in the authorised declarant guide.

Default value or verified figure

• Default value: the EU value for China and that product, with a 10 % mark-up in 2026 (Annex IV, point 4.1). It is not verified.
• Actual figure: that of the supplier’s installation, verified by an accredited verifier (Article 8). If the supplier is registered as an operator, it shares it with you in the CBAM registry and you can use it directly (Article 8(2)).

In the example, if the tube comes from a verified factory buying from a verified steel plant (1.7 t of CO₂ per tonne), the declaration drops from about €125,939 to about €52,773. What to ask your supplier to have it in time is in the Chinese supplier letter; what each tonne costs year by year, in the CBAM cost per tonne guide.

Certificates: price, purchase and surrender

• Price for 2026 imports: the quarterly average of EU ETS closing prices in the quarter of import (Article 21(1a)). Published: €75.36 in the first quarter, €75.28 in the second and €82.32 in the third. The fourth is published in January 2027.
• Purchase: from 1 February 2027, on the common central platform, for authorised declarants only.
• Surrender: by 30 September 2027, in the CBAM registry (Article 22(1)).
• Any surplus: certificates bought in 2027 for 2026 emissions can only be repurchased in 2027, on a request made by 31 October (Article 23); any left are cancelled without compensation on 1 November 2027 (Article 24(2)).
• A carbon price paid in China: reduces the certificates only with verified actual emissions, effective payment, rebates deducted and documentation certified by an independent person (Article 9).

The dates, from now to November 2027

• Until 31 December 2026: every tonne imported goes into the declaration. What the supplier does not measure in 2026 cannot be verified.
• January 2027: verifiers start issuing the 2026 reports in the CBAM registry, and the fourth-quarter price is published.
• 1 February 2027: certificates go on sale. From 2027 the 50 % quarterly holding also applies to what you import that year.
• 30 September 2027: the 2026 declaration and surrender of certificates.
• 31 October 2027: last day to request the repurchase of any surplus.
• 1 November 2027: 2026 certificates left on the account are cancelled.
• Until 31 December 2031: keep the calculation records, the verification reports and the proof of any carbon price paid (Articles 7(6) and 9(3)).

Who files it

The authorised declarant, which may delegate the submission to a person acting on its behalf and in its name, such as its customs agent or a consultant. The responsibility stays with the declarant (Article 5(7a)). If you import through an indirect customs representative acting as declarant, the declaration for those goods is theirs.

If you do not surrender in time

For each certificate not surrendered by 30 September, the penalty is the EU ETS excess emissions penalty (€100 per tonne of CO₂, indexed to inflation), and paying it does not release you from surrendering the missing certificates (Article 26). It can be reduced where the error comes from incorrect information from an operator or a verifier (Article 26(1a)).

HeavyDeals keeps the tonnes, CN code and supplier of every import from the purchase order, with its default value or verified figure, so the declaration comes out of what you already have. And with your Chinese suppliers we prepare the figure that lowers the bill (CBAM at HeavyDeals).

Every figure and rule was checked against the sources above, on the date shown next to each; last review of this guide: 27 October 2026. The examples use illustrative figures, not today’s quotes. This is not legal or tax advice. Written with the help of AI and reviewed by the HeavyDeals team.