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CBAM returned goods: how to declare zero embedded emissions under Art. 6(5)

Art. 6(5) of Reg. (EU) 2023/956 provides that returned goods — EU-origin goods reimported under Art. 203 of the Union Customs Code — shall be declared with zero embedded emissions in the CBAM declaration. This means no CBAM certificates are required for these goods. But the returned-goods status must be properly documented. CBAMCheck generates 12 structured documents including a scope assessment that identifies and separates returned goods from standard CBAM imports.

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 returned goods

Art. 6(5)
Returned goods are declared with zero embedded emissions in the CBAM declaration
Art. 203 UCC
Union Customs Code provision for returning goods — the customs basis for CBAM exemption
Zero certificates
No CBAM certificates required for properly documented returned goods

How to handle CBAM returned goods step by step

1
Identify returned goods in your import portfolio
Distinguish goods that qualify as returned goods under Art. 203 UCC from standard third-country imports. Only EU-origin goods being reimported qualify.
2
Document the original export
Maintain proof that the goods were originally exported from the EU customs territory. Export declarations, certificates of origin and transit documents.
3
Apply Art. 203 UCC customs treatment
Ensure the goods are declared under Art. 203 at customs. The CBAM returned-goods treatment (Art. 6(5)) follows the customs classification.
4
Declare zero embedded emissions in your CBAM declaration
Art. 6(5): include the returned goods in your CBAM declaration but report zero embedded emissions. No certificates are required for these goods.
5
Keep documentation for verification
Art. 8 verification may review your returned-goods claims. Maintain the full chain: original export → customs treatment → reimport → zero-emissions declaration.
6
Separate returned goods from standard imports in your records
For Annex V record-keeping, clearly separate returned goods (zero emissions) from standard CBAM imports (calculated emissions). CBAMCheck's scope assessment helps with this classification.

Three mistakes importers make with CBAM returned goods

MISTAKE 1 — CALCULATING EMISSIONS FOR RETURNED GOODS

Treating reimported EU-origin goods as standard CBAM imports

Art. 6(5) explicitly provides zero embedded emissions for returned goods. Calculating and paying for certificates on goods that already carried EU carbon costs is unnecessary.

MISTAKE 2 — POOR DOCUMENTATION OF RETURNED-GOODS STATUS

Not linking the reimport to the original export under Art. 203

The zero-emissions treatment requires that the goods qualify under Art. 203 UCC. Without proper documentation linking the reimport to the original export, the goods may be treated as standard CBAM imports.

MISTAKE 3 — NOT SEPARATING RETURNED GOODS IN RECORDS

Mixing returned goods with standard imports

Annex V record-keeping requires clear documentation. Mixing returned goods (zero emissions) with standard imports (calculated emissions) creates confusion during Art. 8 verification.

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)).

Managing both standard CBAM imports and returned goods across multiple companies?

The Professional Pack covers 70 dossier generations. CBAMCheck's scope assessment separates returned goods from standard imports in every dossier.

Request Professional Pack →
70 generations · 1 key · Returned goods + standard imports handled per dossier

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.
What are returned goods under CBAM?
Returned goods are EU-origin goods that were exported and then reimported under Art. 203 of the Union Customs Code. Under Art. 6(5) of Reg. (EU) 2023/956, they are declared with zero embedded emissions in the CBAM declaration.
Do I still need to include returned goods in my CBAM declaration?
Yes. Returned goods must be included in your annual CBAM declaration (Art. 6), but with zero embedded emissions. They are part of your declaration but do not generate a certificate obligation.
⚠️ 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.

Returned goods = zero CBAM certificates. But only if properly documented.

12 deliverables. Scope assessment separating returned goods. Art. 6(5) documentation. Record-keeping. €299.

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