The EU Carbon Border Adjustment Mechanism entered its definitive period on 1 January 2026. For affected importers, the CBAM registry is no longer simply a transitional reporting system. It is now the central platform for managing authorisation, embedded-emissions information and CBAM certificate obligations.
This introduces real customs, operational and financial consequences. Businesses importing covered goods above the relevant threshold must hold authorised CBAM declarant status or qualify under an exemption or temporary arrangement. Failure to comply could result in penalties, customs delays or imports being blocked.
What is the CBAM registry?
The CBAM registry is the European Commission’s electronic system for administering the Carbon Border Adjustment Mechanism.
During the definitive period, it connects importers, indirect customs representatives, national competent authorities, installation operators and accredited verifiers. Its main functions include:
- Managing authorised CBAM declarant status
- Recording CBAM account and authorisation details
- Exchanging embedded-emissions information
- Submitting annual CBAM declarations
- Recording and surrendering CBAM certificates
- Supporting customs and regulatory checks
Access is normally arranged through the national competent authority in the EU Member State where the applicant is established.
The European Commission provides official access information and user guidance on its CBAM Registry and Reporting page.
How has the CBAM registry changed?
The CBAM transitional period ran from 1 October 2023 to 31 December 2025. During that period, declarants submitted quarterly reports covering imported goods and their embedded emissions. There was no requirement to purchase or surrender CBAM certificates.
The definitive period is different in three important ways:
- Affected imports are generally linked to an authorised CBAM declarant.
- Annual declarations replace transitional quarterly reports.
- Embedded emissions create a financial obligation through CBAM certificates.
The definitive CBAM registry is therefore an import-compliance and financial-management system, rather than a reporting portal alone. Processes used during the transitional period will not be sufficient for definitive-period compliance.
Who needs access to the CBAM registry?
An authorised CBAM declarant is an EU importer or, in certain circumstances, an indirect customs representative authorised by the relevant national competent authority.
Importers exceeding the single mass-based threshold of 50 tonnes per calendar year generally need authorised CBAM declarant status. The threshold is based on the importer’s cumulative net mass during the year – not on each shipment.
The 50-tonne threshold applies collectively to covered goods in these sectors:
- Iron and steel
- Aluminium
- Cement
- Fertilisers
Electricity and hydrogen are not covered by the mass-based exemption. Importers of these goods may therefore need CBAM authorisation regardless of import volume.
Businesses must also check each product’s eight-digit Combined Nomenclature – or CN code. A general description such as “steel parts” is not enough to determine whether a product falls within CBAM.
The European Commission’s CBAM definitive regime guidance provides an official summary of the sectors, threshold and importer obligations.
Importers that expect to exceed the threshold should apply before importing, or before further imports take them above it. Those remaining below the threshold should still monitor cumulative quantities carefully across all consignments and customs agents.
A temporary provision applies to businesses that submitted an authorisation application by 31 March 2026. These applicants may provisionally continue importing while their national competent authority considers the application, subject to the applicable conditions.
When is the first CBAM declaration due?
The first annual CBAM declaration will cover imports made between 1 January and 31 December 2026.
It must be submitted through the CBAM registry by 30 September 2027. The corresponding CBAM certificates must also be surrendered by the same date.
The deadline was changed from 31 May under the EU’s 2025 simplification amendments. Businesses using older guidance should update their compliance calendars accordingly.
The amended deadline is set out in Regulation (EU) 2025/2083.
How will CBAM certificates work?
One CBAM certificate represents one tonne of CO₂-equivalent embedded emissions.
Certificate prices are linked to EU Emissions Trading System allowance prices. For emissions arising from 2026 imports, prices are based on quarterly averages of EU ETS auction prices. From 2027, certificate prices move to weekly averages.
Although the definitive period began in January 2026, declarants do not purchase CBAM certificates during 2026. Member States will begin selling certificates through the common central platform from 1 February 2027, including certificates required for 2026 imports.
Certificate transactions and account balances will be connected to the CBAM registry. Certificates are surrendered annually rather than quarterly.
From 2027, authorised CBAM declarants must ensure that the certificates in their accounts at the end of each quarter correspond to at least 50% of the embedded emissions in covered goods imported since the start of that year. This quarterly balance requirement does not apply during 2026.
A reduction may be claimed where a declarant can prove that a carbon price was effectively paid in the country of origin. The evidence must meet EU requirements and account for rebates or other compensation received by the producer.
What should authorised CBAM declarants prepare?
Businesses should treat the CBAM registry as part of their customs, emissions-data and financial-control processes.
Key actions include:
Confirm product scope
Review the eight-digit CN codes used on customs declarations and compare them with the goods listed in the CBAM legislation.
Monitor the 50-tonne threshold
Track cumulative net mass across all relevant goods, consignments and customs agents at importer level.
Confirm declarant responsibility
Determine whether the EU importer or an indirect customs representative will act as the authorised CBAM declarant.
Check customs information
Ensure declarations include the correct EORI and CBAM account details – or a valid application reference where the temporary arrangement applies.
Collect supplier emissions data
Identify the installations producing the imported goods and request emissions information in the required format. Actual emissions may need verification by an accredited verifier.
Forecast certificate costs
Estimate embedded emissions and potential certificate liabilities using EU ETS-linked prices. Although certificates are not purchased until 2027, the financial liability begins with 2026 imports.
Maintain supporting records
Retain customs data, calculations, supplier information, verification reports and evidence of carbon prices paid abroad.
What happens if CBAM obligations are missed?
Customs authorities can check whether an importer holds the correct CBAM account number or protected application reference. Imports may be delayed or refused where the required conditions have not been met.
Failure to surrender the correct number of certificates can result in a financial penalty for each missing certificate. Paying the penalty does not generally remove the obligation to surrender the outstanding certificates.
Serious or repeated non-compliance could also lead to investigation and the suspension or revocation of authorised declarant status.
Make the CBAM registry part of your import controls
The definitive CBAM registry turns CBAM into a practical import and financial obligation. Affected businesses require the correct authorisation, accurate classifications, reliable supplier information and a realistic certificate budget.
Although the first declaration is not due until 30 September 2027, it covers imports throughout 2026. Every affected shipment therefore contributes to the emissions data and financial liability that must eventually be reconciled through the CBAM registry.
Get CBAM support from Allied Group
CBAM brings together customs classification, importer responsibility, supplier emissions and financial planning.
Allied Group can help businesses assess product scope, monitor the 50-tonne threshold and prepare for definitive-period obligations.
Speak to Allied Group about CBAM compliance and customs support before an authorisation, classification or emissions-data issue disrupts your imports.
