CBAM deadlines for exporters: what happens in 2026 and 2027

The EU deadlines apply to your buyers, not to you. But every one of them turns into a request in your inbox, usually months earlier.

Reviewed by the Carbon Passport compliance team, Singapore. Updated and checked against official EU sources on 28 September 2026. Rules change often; we update this page when they do.

Quick answer

CBAM's definitive regime began on 1 January 2026. Certificate sales open on 1 February 2027, and the first annual declaration and certificate surrender for 2026 imports are due by 30 September 2027. Default value mark-ups rise from 10% in 2026 to 20% in 2027 and 30% from 2028.

The timeline

DateWhat happensWhat it means for you
1 Jan 2026Definitive regime starts. Importers above 50 tonnes a year must be authorised CBAM declarants.Every EU shipment of CBAM goods in 2026 will need emissions data.
2026Default values apply with a 10% mark-up. The Commission publishes guidance for non-EU operators, including a sector guide for aluminium, in August 2026.Buyers start collecting supplier data and comparing it with defaults.
1 Jan 2027Default value mark-up rises to 20%.Not having data gets more expensive for your buyer.
1 Feb 2027CBAM certificate sales open, priced from 2026 quarterly EU carbon prices.Buyers know their real 2026 bill and look hard at supplier data.
By 30 Sep 2027First annual declaration and surrender for 2026 imports.Buyers will want verified data well before this, often by mid-2027.
1 Jan 2028Default value mark-up rises to 30%.The gap between good data and defaults widens again.

When your buyers will actually ask

Most importers work backwards from 30 September 2027. They need time to check supplier data, get it verified and prepare the declaration. Expect requests for 2026 data from now through the first half of 2027, with firm internal deadlines of a few weeks each.

What to do in each phase

Now to end of 2026

  • Keep fuel, production, metal purchase and scrap records by month and by product.
  • Answer the first requests quickly, even with provisional numbers, so buyers can plan.
  • Ask your metal suppliers for their CBAM data.
  • Decide whether to verify your 2026 data, and contact verifiers if so.

Early 2027

  • Finalise full-year 2026 figures for each product and installation.
  • Complete verification, including the first site visit.
  • Send final data packs to every EU buyer, and consider registering your installation in the CBAM Registry.

From mid-2027

  • Repeat for 2027 data. It gets easier once your monitoring and records are set up.
  • Watch for rule changes: benchmarks and default values are being revised, and the Commission is reviewing CBAM's scope.

Notes for exporters in Asia

Suppliers in Vietnam, Indonesia, Thailand and India often sell to several EU buyers through traders. Each buyer may send a different format for the same data. A single, well-documented data pack per installation and year, reused across buyers, saves most of the effort. If a trader sits between you and the importer, the trader will pass your data on, so make sure your company name and installation details are exactly right.

Got a request you're not sure about?

Send us what your buyer sent. We'll tell you what they need and what it will take, free, within one week.

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Frequently asked questions

When is the first CBAM declaration due?

By 30 September 2027, covering goods imported into the EU during 2026. Certificates for 2026 can be bought from 1 February 2027.

Do CBAM deadlines apply to non-EU suppliers?

The legal deadlines apply to EU importers. Suppliers are affected because importers need their emissions data to meet those deadlines, usually much earlier.

Will CBAM rules change again?

Very likely. Default values have already been corrected once in 2026, benchmarks are being revised, and the Commission is reviewing scope. Check the Commission's CBAM pages before each reporting cycle.

Sources

This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.

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