Everything that goes into a CBAM report

Only the authorised declarant files. That is the importer of record established in the EU, or an indirect customs representative acting on their behalf. If you manufacture in Albania, North Macedonia or Montenegro and sell to a German buyer, you never touch the registry — but the declarant cannot file without you, which is why the request lands in your inbox.

Since the definitive period opened on 1 January 2026, importers below 50 tonnes of CBAM goods a year are fully exempt.

• CN code and quantity — straight off the customs declaration.
• Installation identifier — the specific plant, not the company.
• Specific embedded emissions — direct, plus indirect where they count.
• Production route — the same product made two ways carries two numbers.
• Carbon price already paid — with evidence, if you claim the deduction.

You may use the Commission's default values instead of measured emissions. They are set deliberately high, because they exist to remove any incentive to withhold real data. For most Balkan producers — particularly those on hydro-heavy grids — actual installation-level figures come in materially below the default, and the gap is the whole commercial argument for measuring properly.

Certificate sales open on 1 February 2027. The annual declaration for goods imported during 2026, and the surrender of certificates against it, are both due by 30 September 2027.

It is not an ESG report, a sustainability statement or a carbon footprint in the marketing sense. Nobody reads it for reputation. It is a customs filing that produces a certificate liability, and it is assessed on whether the numbers can be substantiated — not on whether they are impressive or improving.

That distinction matters for who inside a company should own it. A CBAM report is a finance and operations responsibility with a compliance deadline, not a communications project.

The declarant needs, per installation and per production route: the specific direct embedded emissions per tonne of product, the specific indirect emissions where the sector requires them, the electricity consumption and the emission factor applied to it, the production route used, and any carbon price already paid with evidence.

Most suppliers can assemble this from records they already keep — fuel purchase invoices, electricity bills, production logs. What they usually cannot do is produce it in a form that survives a question about where a figure came from, which is the part that takes preparation rather than effort.

• Counting only fuel. Process emissions from calcination or reduction do not appear in any energy bill, and omitting them understates a cement or steel footprint badly.
• Using a European average electricity factor. On regional grids this can be wrong by multiples, in either direction.
• Reporting at company level. CBAM is installation-level. A group figure is not an answer.
• Discarding the source documents. A figure whose invoice is gone becomes an estimate the moment a verifier asks.