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CBAM importer obligations in the EU: the complete guide for all member states

The Carbon Border Adjustment Mechanism (CBAM) applies identically in all 27 EU member states under Reg. (EU) 2023/956. You apply for authorisation as a CBAM declarant through the EU CBAM Registry, and your application is reviewed by the NCA of the member state where your company is established (Art. 5 + Art. 17). Once authorised, your status is valid across the entire EU — you do not need separate authorisations per country. CBAMCheck generates 12 structured documents that prepare your data for the CBAM Registry, regardless of which NCA oversees your compliance.

Generate your CBAM dossier — €299Free check: does CBAM affect you?

€299 · One-time · 12 professional deliverables · Your data never leaves your browser

Built on Reg. (EU) 2023/956 · Modified by Reg. (EU) 2025/2083 · 13,566 default values (Reg. 2025/2621) · 100% browser-side — your data never leaves your device

The numbers that matter for CBAM importers across the EU

27 NCAs
Each member state has a designated NCA — you report to the one where your company is established (Art. 17)
EU-wide validity
CBAM authorisation granted in one member state is valid across all 27 (Art. 17(1))
30 Sept 2027
First annual CBAM declaration deadline (Art. 6) for CY 2026 — same in all member states

Your step-by-step CBAM compliance timeline — applicable in every EU member state

1
Apply for authorisation as CBAM declarant
Art. 5. Submit through the EU CBAM Registry. Your NCA is determined by where your company is established, not where goods enter the EU. The authorisation is valid EU-wide (Art. 17(1)).
2
Identify all CBAM goods in your import portfolio
Check CN codes against Annex I. Six sectors: cement, iron and steel, aluminium, fertilisers, hydrogen and electricity. De minimis: 50 tonnes/year (Art. 2a). Same threshold everywhere.
3
Collect emissions data from your third-country suppliers
Request actual emissions data. If unavailable, default values from Implementing Reg. (EU) 2025/2621 apply with a 10% mark-up (Annex IV, point 4.1). 13,566 default values cover all sectors and origins.
4
Purchase CBAM certificates quarterly
Art. 22(2): hold certificates covering ≥50% of embedded emissions at the end of each quarter. Certificates are priced at the EU ETS auction rate (Art. 21). Same price across all member states.
5
Submit your annual CBAM declaration by 30 September
Art. 6: first declaration due 30 September 2027 for CY 2026. Includes quantities, total embedded emissions, certificates surrendered and Art. 9 carbon price deductions.
6
Undergo verification by an accredited verifier
Art. 8 + Annex VI: embedded emissions must be verified by an accredited verifier before declaration submission. The verifier can be from any EU member state.

Three compliance mistakes EU importers should avoid

MISTAKE 1 — APPLYING TO THE WRONG NCA

Confusing port of entry with country of establishment

You apply for CBAM authorisation in the member state where your company is established — not where goods physically enter the EU. A German company importing through Rotterdam still reports to the DEHSt, not the NEa.

MISTAKE 2 — ASSUMING SEPARATE AUTHORISATIONS PER COUNTRY

Applying in multiple member states

CBAM authorisation is valid EU-wide (Art. 17(1)). You apply once in your member state of establishment. If you import through ports in Belgium, the Netherlands and Italy, you still need only one authorisation.

MISTAKE 3 — TREATING CBAM AS AN ANNUAL-ONLY OBLIGATION

Ignoring the quarterly certificate requirement

Art. 22(2) requires quarterly certificate purchases covering ≥50% of embedded emissions. This is a continuous obligation throughout the year, not just an annual filing.

What you receive: 12 deliverables in one ZIP file

CBAMCheck generates a complete CBAM compliance dossier — not a single PDF. 12 structured documents delivered as a ZIP file, each citing the specific article of Reg. (EU) 2023/956 it addresses.

1

Scope Assessment

Determines whether your imports fall under CBAM and which obligations apply. Art. 2 + Art. 2a of Reg. (EU) 2023/956.

2

Embedded Emissions Calculation

Calculates embedded emissions per tonne using default values from Implementing Reg. (EU) 2025/2621 or your actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Estimates the number of certificates required and the projected cost, adjusted for free allocation (Art. 31).

4

Draft CBAM Declaration

Pre-structured declaration following Art. 6(2) requirements: quantities, emissions, certificates, carbon price.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction. Pre-formatted for the CBAM Registry.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements. Ready for verifier review.

7

Verification Preparation

Structured preparation for Art. 8 verification by an accredited verifier. Annex VI checklist included.

8

Supplier Letter Template

Model letter in English requesting emissions data and installation information from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations (Art. 22(2)), annual declaration deadline (30 September), and key milestones.

10

Executive Summary

One-page overview of your CBAM exposure: cost estimate, timeline, risk areas. Ready for management or board reporting.

11

Interactive HTML Dashboard

Standalone HTML dashboard with 2026–2032 projections reflecting free allocation phase-out (Art. 31). Works offline, no subscription.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines, reporting windows and certificate purchase schedules.

Generated from your input data, in your browser. No data leaves your device.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company's actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emissions calculations.

Estimate your CBAM exposure

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What CBAM compliance costs with each alternative

FeatureFree toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoHTML, 7-year projectionPlatform-locked
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoVia Professional PackYes

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML dashboard (2026–2032 projection)
  • 13,566 official default values integrated
  • English supplier letter template
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
PROFESSIONAL PACK
€1,999
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs brokers
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription. The 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

The EU CBAM portal ASKS for data. CBAMCheck CALCULATES it.

THE EU CBAM PORTAL

Asks you to declare data

The EU CBAM Registry (Art. 14) requires you to submit total embedded emissions, number of certificates and carbon price documentation. It does not calculate these for you. You must arrive with the numbers ready.

CBAMCHECK

Calculates the data you need to declare

CBAMCheck takes your import data (tonnes, CN codes, country of origin) and generates the embedded emissions calculation, certificate estimation, carbon price documentation and all supporting records. You download the dossier and use it to complete your declaration in the CBAM Registry.

Enforcement: what happens when CBAM certificates are missing

Art. 26 of Reg. (EU) 2023/956 sets the penalties.

⚠️
Authorised declarant: penalty identical to EU ETS rate
EU ETS rate per certificate

Art. 26(1): an authorised CBAM declarant who fails to surrender the required certificates by 30 September faces a penalty identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased per Art. 16(4). The penalty applies per certificate not surrendered. Payment does not release the obligation to surrender outstanding certificates (Art. 26(3)).

⚠️
Unauthorised importer: penalty 3–5 times the standard rate
3–5×

Art. 26(2): anyone introducing goods without authorisation faces a penalty of 3 to 5 times the standard penalty, depending on duration, gravity, scope, intent and cooperation. Also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Operating across multiple EU member states with CBAM imports through several ports?

The Professional Pack covers 70 dossier generations. One key for 70 complete dossiers — ideal for companies importing through multiple EU ports and reporting to one NCA.

Request Professional Pack →
70 generations · 1 key · Switch product, origin and sector between runs

What CBAMCheck guarantees and what it does not

CBAMCheck generates a document structured according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 from the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer or authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours forever.
Can I request a refund?
By activating the licence you give express consent for the immediate generation of digital content under Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for reproducible technical faults.
What if the regulation changes?
If the regulation changes during your licence validity, you can regenerate the document with the updated version of the generator at no extra cost.
How do I find my NCA?
Your NCA is the authority designated by the member state where your company is established (Art. 17). The European Commission maintains a list of all 27 NCAs on its CBAM information page. CBAMCheck also publishes country-specific landing pages identifying each NCA.
Is CBAM authorisation valid across the EU?
Yes. Art. 17(1) of Reg. (EU) 2023/956 provides that CBAM declarant authorisation granted in one member state is valid for importing CBAM goods into any EU member state. You do not need separate authorisations per country.
What if my company operates in multiple EU countries?
You apply for authorisation in the member state where your company is established. If you have subsidiaries in other member states, each subsidiary applies separately through its own NCA. The authorisation of each entity is EU-wide.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

One EU regulation. 27 NCAs. One authorisation valid EU-wide. Get your documentation ready.

12 deliverables. Works for any EU member state. Emissions calculation. Certificate estimation. Art. 8 verification prep. €299.

€299 one-time
12 professional deliverables · Browser-side · No subscription · Reg. (EU) 2023/956
Generate your CBAM dossier — €299