Who has to submit a CBAM report
From 2026, the reporting obligation does not arise automatically for all importers: a de minimis threshold of 50 tonnes of goods per year per importer applies, calculated across all CBAM goods together (except electricity and hydrogen, where the threshold does not apply). If the combined annual imports of cement, iron and steel, aluminium or fertilisers into the EU exceed the threshold, authorised CBAM declarant status is required, along with reporting based on the actual emissions of the producer; default values are allowed only as an exception and to a limited extent.
A typical mistake is to assume the obligation only concerns the producer in the EU. Responsibility for submission lies with the importer (declarant) or its customs representative, while the emissions data must be provided by the producer outside the EU. If the report is not prepared according to the EU Implementing Regulation, the declarant will technically be unable to upload it to the registry. This is where time is most often lost, even before verification.
The cost of being late is more than a penalty
For each CBAM certificate not surrendered, there is a penalty of €100 per tonne of emissions (indexed to EU inflation), and paying the penalty does not release the declarant from the obligation to surrender the certificates. If the breach is repeated in subsequent reporting periods, the penalty is charged again, not just once.
A less obvious risk: repeated discrepancies or delays can lead to the refusal of authorised declarant status. Without this status, importing CBAM goods into the EU has been legally impossible since 2026. The issue goes beyond penalties and concerns your very ability to keep exporting.
How we prepare the report
Input data
Customs declarations, the producer's production specifications and energy consumption data. We provide a ready-made template so that collecting the producer's data is as simple and fast as possible.
Calculation
Direct and indirect emissions using the methodology of the EU Implementing Regulation, not a simplified calculator. This is the difference between a report that is accepted the first time and one that is sent back.
Check
We check the report's compliance with EU legislation (the CBAM Regulation). Discrepancies are corrected before submission, not after a rejection.
Submission
You receive a finished report that your authorised declarant can upload to the CBAM Registry successfully and without technical problems, together with recommendations for the next reporting period.
What we need from you to get started
To get started we need three things: copies of customs declarations for the reporting period, a contact for the producer's technical specialist (not the sales department, but someone who knows the production process), and any previous CBAM reports, if they have already been submitted.
Is the reporting period deadline approaching?
Call us: in 15 minutes we will tell you whether you have an obligation and how much time is left before submission.
Frequently asked questions
About preparing CBAM reports and declaration data.
Does CBAM apply to my company if I export less than 50 tonnes a year?
From 2026, a de minimis threshold of 50 tonnes per year per importer applies. If the combined volume of all CBAM goods (except electricity and hydrogen, to which the threshold does not apply) is lower, there is no formal obligation to report or to purchase certificates. The threshold is calculated across all product categories together, not separately for each, so it is worth calculating your actual annual volume rather than going by a single shipment or a single product.
How much does a CBAM report cost and what does the price depend on?
The cost depends on the number of product categories, CN (UKTZED) codes and production lines, the availability of ready data from the client, and urgency. We quote the exact price by phone right after a short description of your situation.
What if a supplier refuses to provide emissions data?
Temporarily (and to a limited extent) you can use the default values set by the European Commission for the sector, but they are usually higher than actual values, which increases the cost of certificates. We prepare a template and a cover letter for suppliers that significantly improve the chances of obtaining actual data.
How is your report different from a free online CBAM calculator?
Online calculators use simplified factors and do not stand up to a detailed review by an accredited verifier. Our calculation follows the full methodology of the EU Implementing Regulation.
Not a good time to call right now?
Tell us a convenient time in your message and we will call you back with the exact report preparation timeline.