Quarterly reports must be submitted within one month of the end of each quarter during the transitional period. Q1 reports are due by 30 April, Q2 by 31 July, Q3 by 31 October, and Q4 by 31 January of the following year. Starting from 2026, annual CBAM declarations are due by 31 May for the prior calendar year.
Who is legally responsible for filing — the importer or the exporter?
The EU importer (or their indirect customs representative under role 02) is legally responsible. Non-EU exporters have no direct obligation under CBAM, but in practice most of the data collection burden falls on them because the importer needs production-level emission data only the supplier has.
Do I need third-party verified emission data?
During the transitional phase (October 2023 – December 2025), verification is not required and EU default values may be used when actual data is unavailable. From January 2026 onward, actual emissions data verified by an EU-accredited third-party verifier becomes mandatory for most goods.
Which products are covered by CBAM?
Six sectors currently fall under CBAM — iron and steel, aluminum, cement, fertilizers, hydrogen, and electricity. Downstream products, chemicals, and polymers are expected to be added in future phases.
What happens if I submit incomplete or incorrect data?
Penalties for late, incomplete, or inaccurate reports range from 10 to 50 EUR per tonne of undeclared embedded emissions. Falsified data can trigger fines up to three times the CBAM certificate price, and repeat or severe infractions can lead to loss of import authorization.
What format does the CBAM Transitional Registry accept?
The registry accepts XML files that conform to the official QReport schema (currently `QReport_ver23.00.xsd`). Formist generates this XML automatically after you upload your commercial invoices, supplier emission data, and CN code mappings.