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Carbon Border Adjustment Mechanism

The Carbon Border Adjustment Mechanism (CBAM) is an EU instrument for preventing carbon leakage, that is, release of emissions to non-EU countries.

The mechanism is applied to so-called CBAM goods imported into the EU from outside the EU. These goods include certain iron and steel goods, fertilisers, aluminium and cement goods as well as hydrogen and electricity.
 

What the importer must do

During the CBAM transition period 2023–2025, the importer must report emissions from CBAM goods to the Commission. Read more in the instructions for the transition period.

 

The obligations change from 1 January 2026. To import CBAM goods, you need the authorised CBAM declarant status. Apply for the authorisation already during 2025. Read more about the authorisation and other obligations. 

Who do the new obligations apply to?

The obligations apply to all who import CBAM goods. Imports mean any imports to EU from outside the EU, including e.g. imports of goods ordered online and imports of gifts.

The goods listed here which are imported from outside the EU comprise CBAM goods:.  

  • certain iron and steel goods
    • Derivative goods such as screws, bolts and washers.
  • iron ore
  • certain fertilisers
  • certain aluminium goods
  • certain cement goods
  • certain chemicals
  • electricity.

Note that a report is required only for CBAM goods that are released for free circulation within the EU. You do not have to report any goods when they are not declared for entry to EU territory (e.g. temporary admission or inward processing). 

Goods for which a report is not required

  • Goods, which under the rules of origin originate in the EU.  
  • Goods which, under to the rules of origin, originate in Iceland, Liechtenstein, Norway and Switzerland (EEA countries). 
    • Please note that the import country is not significant in terms of the reporting obligation, rather the country of origin of the goods.   For example, if you bring in goods from Switzerland that are of Chinese origin, you must report on the goods emissions.
  • goods originating in the territories of Büsingen, Helgoland, Livigno, Ceuta or Melilla (special territories in the EU).
  • consignments of low value, i.e. no more than 150 euros (Duty Relief Regulation, Article 23)
    • Example: You receive a consignment from outside the EU that contains both CBAM goods (e.g. screws) and other goods. The total value of the consignment is more than 150 euros. If the value of the CBAM goods (screws) in the consignment is 150 euros or less, it is considered a low-value consignment and you don’t have to report their emissions to the Commission. 
      The calculated value of the consignment only concerns CBAM goods without transport costs.
  • CBAM goods brought in personal luggage with a combined value of no more than 150 euros. 
  • goods to be moved or used in the context of military activities pursuant to Article 1, point (49), of Commission Delegated Regulation (EU) 2015/2446.

Please note that this list cannot be used for tariff classification of goods. Always check the correct commodity code in the Fintaric service. The Customs Information Service can help you if needed. Read more on the page How to find the right commodity code.

Cement

You will find these commodity codes in the Fintaric service, under section V of the nomenclature, Minerals.

  • 2507 00 80 Other kaolinic clays
  • 2523 10 00 Cement clinkers
  • 2523 21 00 Portland cement: White cement
  • 2523 29 00 Portland cement: Other
  • 2523 30 00 Aluminous cement
  • 2523 90 00 Other hydraulic cements

Electricity

You will find this commodity code in the Fintaric service, under section V of the nomenclature, Minerals.

  • 2716 00 00 Electrical energy

Chemicals

You will find this commodity code in the Fintaric service, under section VI of the nomenclature, Products of the chemical or allied industries

  • 2804 10 00 00: hydrogen as pure substance

Fertilisers

You will find these commodity codes in the Fintaric service, under section VI of the nomenclature, Products of the chemical or allied industries.

  • 2808 00 00: Nitric acid; sulphonitric acids as pure substance
  • 2814 Ammonia, anhydrous or in aqueous solution
    • 2814 10 00 00    - Anhydrous ammonia (gaseous ammonia NH3)
    • 2814 20 00 00    - Ammonia in aqueous solution (solution NH4OH)
    • Both above as pure substance
  • 2834 21 00 Potassium nitrate as pure substance
  • 3102 Mineral or chemical fertilisers, nitrogenous. This commodity code covers, among others
    • Urea, whether or not in aqueous solution
    • Ammonium sulphate; double salts and mixtures of ammonium sulphate and ammonium nitrate
    • Ammonium nitrate, solid or in aqueous solution (also for other use than as fertiliser), mixtures with calcium carbonate or other inorganic non-fertilising substances
    • Sodium nitrate
    • Mixtures of urea and ammonium nitrate in aqueous or ammoniacal solution
  • 3105 (Fertilisers or mixtures of fertilisers) Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus and potassium; other fertilisers; goods of this chapter in tablets or similar forms or in packages of a gross weight not exceeding 10 kg:
    • (excluding 3105 60 00 Mineral or chemical fertilisers containing the two fertilising elements phosphorus and potassium)

Iron and steel

You will find this commodity code in the Fintaric service, under section V of the nomenclature, Minerals.

  • 2601 12 00 Agglomerated iron ores and concentrates, other than roasted iron pyrites

You will find these commodity codes in the Fintaric service, under section XV of the nomenclature, Base metals and articles of base metal.

  • 72 Iron and steel:
    • Primary materials; products in granular or powder form
      • (excluding the following ferro-alloys: 7202 2 ferro-silicon, 7202 3 ferro-silico-manganese, 7202 50 00 ferro-silico-chromium, 7202 70 00 ferro-molybdenum, 7202 80 00 ferro-tungsten and ferro-silico-tungsten, 7202 91 00 ferro-titanium and ferro-silico-titanium, 7202 92 00 ferro-vanadium, 7202 93 00 ferroniobium, 7202 99 10 ferro-phosphorus, 7202 99 30 ferro-silico-magnesium, 7202 99 80 other, 7204)
    • Iron and non-alloy steel
    • Stainless steel 
    • Other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel
  • 73 Articles of iron or steel:
    • 7301 Sheet piling of iron or steel; angles, shapes and sections of iron or steel
    • 7302 Railway or tramway track construction material of iron or steel
    • 73 03 –73 06 Tubes and pipes of iron or steel
    • 7307 Tube or pipe fittings
    • 7308 Structures and parts of structures, of iron or steel 
    • 7309 Reservoirs, tanks, vats and similar containers, of a capacity exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
    • 7310 Tanks, casks, drums, cans, boxes and similar containers, of a capacity not exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
    • 7311 Containers for compressed or liquefied gas 
    • 7318 Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles 
    • 7326 Other articles of iron or steel

Aluminium

You will find these commodity codes in the Fintaric service, under section XV of the nomenclature, Base metals and articles of base metal.

  • 7601 Unwrought aluminium 
  • 7603 Aluminium powders and flakes 
  • 7604 Aluminium bars, rods and profiles 
  • 7605 Aluminium wire
  • 7606 Aluminium plates, sheets and strip, of a thickness exceeding 0,2 mm 
  • 7607 Aluminium foil of a thickness not exceeding 0,2 mm 
  • 7608 Aluminium tubes and pipes
  • 7609 00 00 Tube or pipe fittings, for example, couplings, elbows, sleeves
  • 7610 Aluminium structures and parts of structures; aluminium plates, rods, profiles, tubes and the like, prepared for use in structures
  • 7611 00 00 Reservoirs, tanks, vats and similar containers, of a capacity exceeding 300 litres
  • 7612 Casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), of a capacity not exceeding 300 litres
  • 7613 00 00 Aluminium containers for compressed or liquefied gas, for example compressed air bottles
  • 7614 Stranded wire, cables, plaited bands and the like, of aluminium, not electrically insulated:
  • 7616 Other articles of aluminium: Nails, tacks, staples, screws, bolts, nuts, rivets, cotters, cotter pins, washers and similar articles, cloth, grill, netting and fencing, other articles of aluminium

  • Find out whether your import goods are CBAM goods covered by the CBAM regulation.
  • Make sure that you receive all the information you need for the transitional period reports from the manufacturer or seller of the goods.
  • You will need an EORI number for importing and reporting CBAM goods.
  • Create a process for reporting.
  • Gather the import data to be reported from 1 October 2023, and prepare to report to EU’s Commission.
  • To avoid sanctions, please report the data on time, then you can apply for a CBAM declarant certificate
  • Prepare yourself for the time after the transitional period: acquire the CBAM declarant certificate already during 2025.
  • Stay updated on the situation:

Reporting during the transition period 2023–2025

During the transition period 01.10.2023–31.12.2025, importers must report the CBAM goods emissions in the CBAM Transitional Registry. The link to the registry as well as instructions on how to log in and grant mandates, are available on the page CBAM Transitional Registry.

Importers must report on the CBAM goods emissions quarterly to the Commission.

  • Reports are to be submitted to the CBAM Transitional Registry within the given deadline. 
  • You do not need to submit a report if you have not imported any CBAM goods during the reporting period.
     

Who is required to report?

Importers or their representatives submit quarterly reports on the import of CBAM goods to the Commission.

Please note:

  • If you have declared the CBAM goods yourself, you must also submit the report yourself.
  • If you have used a representative, and the representative has declared the goods acting as a direct representative, you must submit the report yourself.
  • If you have used a representative, and the representative has declared the goods acting as an indirect representative, agree with the representative on which one of you will submit the report.

Information to be reported

The following information must be included in the report: quantity of the imported goods, direct and indirect goods emissions, carbon costs (if any) paid in the country of origin, and the resulting compensations.

The calculation method and reporting method for direct and indirect emissions has been specified in the Commission Implementing Regulation. The information to be submitted in the CBAM reports is listed in Annex I of the Regulation.

How to obtain the emissions data for the report

The emissions data must be obtained from the producer of the goods.

On its CBAM information site, under Guidance documents, the Commission has published guidance documents to support importers in collecting emissions data from the manufacturers of the goods.  You can ask the manufacturer to complete the emissions data form (CBAM communication template for installations) and to send it to you. Examples of the filled in form and a guidance video are available in English.

Make sure that you use the latest updated versions of the emission data form and other materials.

You can obtain the emissions data directly from the CBAM Registry, if the producer has added the data to the portal for non-EU installation operators

Non-EU installation operators can also add the emissions data of the CBAM goods they have produced to the CBAM Registry via the portal for non-EU installation operators. In this way, the importer can obtain the emissions data directly also from the CBAM Transitional Registry.

For the importer to be able to obtain the data directly from the CBAM Transitional Registry, the producer of the goods must first log in to the portal and submit the emissions data of their goods there. As an importer, you must inform the producer of your EORI number, so that the producer can allow you access to the data.

You can find the emissions data in the Transitional Registry only if the commodity code and the country of production match the data submitted by the producer. For the report, you also need to find out the production method of the goods from the producer. 

You can find the instructions on the use of data added to the CBAM Registry by the producer under “Submitting a report – example”. 

Guidance and video tutorials for operators on the use of the portal as well as a link to the portal are available on the Commission’s website under ”CBAM Registry access for non-EU installation operators”. If the producer of the goods has any questions relating to the use of the portal, send them to the Commission’s technical support at support@itsmtaxud.europa.eu.

Reporting periods and deadlines for submission of the report

 

Reporting period Deadline for submission  Deadline for modification of the report
October-December 2023 31.1.2024 31.7.2024
January-March 2024

30.4.2024

31.7.2024
April-June 2024

31.7.2024

30.8.2024
July-September 2024 31.10.2024 30.11.2024
October-December 2024 31.1.2025 28.2.2025
January-March 2025 30.4.2025  31.5.2025
April-June 2025 31.7.2025 31.8.2025
July-September 2025 31.10.2025 30.11.2025
October-December 2025 31.1.2026 28.2.2026

After the deadline, you can request a delayed submission of the report. Check the instructions for this in the Guidance for declarants - “Request Delayed Submission.”

You can use one of the following emission calculation methods as emission data from 1 July to 31 December 2024, if the installation uses it:

  • A carbon pricing scheme where the installation is located. 
  • A compulsory emission monitoring scheme where the installation is located. 
  • An emission monitoring scheme at the installation, which can include verification by an accredited verifier.

The use of these alternatives requires that they lead to similar coverage and accuracy of emissions data compared to the methods specified in the CBAM legislation.

If you can’t use any of these alternatives, the emissions data must be reported without flexibilities and be defined in accordance with the CBAM legislation. Verification of the emissions data is not required at this stage; rather the verification system will not be introduced until 1 January 2026.

Using default values

From 1 July 2024, you can only use default values to calculate the emissions of complex goods.

Complex goods are goods produced using other CBAM goods. Up to 20% of the reporting of the total embedded emissions of complex goods defined in the CBAM Regulation can be based on default values.

During the transitional period, the emissions of other goods must be reported based on the actual emissions data. If the reporting is completely based on default values, the report can be considered incorrect according to the CBAM Regulation.

You can amend the report retrospectively

During the transitional period, you can amend the details of the report in the CBAM Transitional Registry within two months of the end of the reporting period.

If you later notice, for example that the report contains errors, or if the manufacturer of the goods has provided you with new corrected emissions data, you can apply for consent from Customs to amend the report. Contact the address cbam@tulli.fi to obtain further instructions. The report can be submitted again within one year of the end of the reporting period.

If the missing details are not entered within the deadline or if the entire report is missing a penalty fee may follow, and obtaining the CBAM declarant certificate may later become more difficult.

Where do I report?

Provide the information in the Commission’s CBAM Transitional Registry

You can find more detailed guidance on the use of the Transitional Registry on the Commission’s website.

If you receive error messages when submitting the report, you can find the messages and guidance on what to do on the Commission’s website, under “Where to report” in the document “CBAM Quarterly Report structure (XLS format)” on the “Error Messages Glossary” tab.

You can change the Transitional Registry language in the “Preferences”, via the profile icon in the upper right corner. Choose the language from the “Preferences” menu.

The Transitional Registry has session timeout. A session timer displayed in the top left corner shows the remaining time before automatic logout.

Please note: In the CBAM Transitional Registry, the fields marked with a red asterisk are mandatory.

1. Prefilling details

2. Start completing the report

3. Add the goods and the emissions information

4. Finish the report

5. Submit the report

6. Making subsequent modifications to the report

7. Proceed as follows if you have not obtained actual emissions data for CBAM reporting

8. How to use emissions data added by the producer to the CBAM Registry via the portal for non-EU installation operators

 

1. Prefilling details

In the CBAM Transitional Registry, you can save e.g. the following details for reports.

Your contact details

  • On the front page, under “My Profile Information”, click on “more”
  • Under “Contact Details”, click on the button “Edit”
  • Type your contact details in the following fields:
    • Contact Person Full name
    • Phone
    • E-mail address
  • Click on “Save”

Adding an operator

‘Operator’ means any person who operates or controls an installation in a third country.

Prefilling the operator details in the registry is not mandatory, but it can speed up the completion of a report, because the details will be available in the registry. If you want to add operators, do this: 

  • On the front page, under “Operators”, click on “more”
  • Click on the blue button “Create an Operator”
  • Enter the operator details in the fields below.
  • In the field “Operator ID”, you can type a chosen combination of numbers and letters
  • Click on “Create”

Adding installations 

‘Installation’ means a stationary technical unit where a production process is carried out.  

Prefilling the details of installations is not mandatory, but it can speed up the completion of a report, because the details will be available in the registry. If you want to add installations, do this:

  • On the front page, in the section “Installations”, click on “more”
  • Click on the blue button “Create an Installation”
  • Fill in the installation details in the fields below
  • In the field “Installation ID”, you can type a chosen combination of numbers and letters
  • Click on “Search in My operator registry”
  • Select the name of the installation operator and click on “Ok” Menu "Select the name of the installation operator"
  • Click on “Create” in the top right corner

2. Start completing the report 

  • On the front page of the Transitional Registry, under “My Quarterly Reports”, click on “more”
  • Create a report:
    • If you wish to create a new report, click on “Create” next to the appropriate reporting period.
    • If you have an XML file, click on “Upload” next to the appropriate reporting period.
    • If you have submitted a report for an earlier reporting period, you can use the previous report as a template. In that case, start completing the report by clicking on “Create using Previous Report” next to the appropriate reporting period.
  • Choose “Header info” on the left side of the page 

“Header info" button

Choose the “Reporting declarant” tab

  • Fill in the contact information.
  • If you are submitting a report on behalf of a company, fill in the details of the company on the tab. Enter the company’s name (or if needed, replace you name with the company’s name) under “Name”.

Field “Name”

  • Under “Role”, choose “Importer for all Goods”
  • Fill in your address details under “Address”
  • Choose the “Importer” tab
    • Tick the box “Declarant acts as importer” if all the goods you are reporting have the same importer. In that case, the program will automatically use this information for each set of goods.

The “Importer” tab

  • Don’t fill in the “Indirect Customs Representative” tab, if you aren’t an indirect customs representative.
  • Note: Indirect customs representative means any operator appointed by another operator to carry out the acts and formalities required under the customs legislation in their dealings with customs authorities. The customs representative can be e.g. a forwarding agency.
  • If you act as an indirect customs representative:
    • On the “Reporting declarant” tab, under “Role”, choose the appropriate alternative.
    • Choose the “Indirect Customs Representative” tab.
    • If you have acted as an indirect customs representative for all the imports you have reported, the box “Declarant acts as representative” should be ticked.

3. Add the goods and their emissions information 

  • Select “Goods imported” on the left side of the page 
    “Goods imported” tab
  • Click on the blue button “Add a good”
  • For the report, you need the first eight digits of the commodity code, the first six being the HS code and the next two the CN code.
  • Under “Commodity”, enter the first six digits of the commodity code in the field “HS sub-heading code”. Choose the appropriate commodity code from the menu that opens.
  • Under “CN code”, choose the next two digits of the commodity code.

The field "CN code".

  • The field “Description of goods” is automatically filled in. The description can be edited.
  • Under “Country of origin”, choose the code for the country of origin
  • Continue in section “1. Requested procedure:”
  • Under “Area of Import”, choose “EU – EU by means of Customs import declaration”, if the goods have been released for free circulation with a customs declaration
  • In the field “Requested procedure”, choose the used customs procedure 
    • For example, 40 – release for free circulation
  • (If needed, under “Previous procedure”, choose the appropriate previous customs procedure.)
  • Under “Goods measure (per procedure)”, in the field “Net mass”, enter the net mass of the imported goods in tonnes.
  • Under “Type of measurement unit”, select “Tonnes” as the measurement unit.
  • If you wish, you can provide additional information on the goods under “Special references for goods”.
  • In the case of the inward processing procedure, proceed as follows:
    • Add the required information under “Inward processing information”.
    • Under “Goods measure (per procedure)”, the box “Inward processing” refers to the following:
      • If you have released CBAM goods for free circulation, don’t tick the box; provide the net mass of the goods.
      • If you have used CBAM goods to produce the goods released for free circulation, tick the box and provide the net mass of the CBAM goods used to produce the goods.
    • In the case of the inward processing procedure, the bill of discharge must be uploaded as an attachment to the report.

“Inward processing information” menu

"Goods measure" menu

  • In the menu on the left, click on the button “Add an emission”. ​​​​

The menu on the left

  • Under “Country of production”, choose the country of production.
  • Add the operator details by clicking on “Add new” under “The company name of the installation”.
    • You can add the details manually.
    • If you have added the operator details in advance, click on “Search in My operator registry”. From the registry, select the operator you have added and click on “OK”. The operator details are filled in automatically.
    • If the operator has already added the details to the CBAM Registry via the portal for non-EU installation operators, read the instructions in section 8.

  • Add the installation details by clicking on “Add new” under “Installation”.
    • You can add the details manually.
    • If you have added the installation details in advance, click on “Search in My Installation Registry”. From the registry, select the installation you have added and click on “OK”. The installation details are filled in automatically.
    • If the operator has already added the details to the CBAM Registry via the portal for non-EU installation operators, read the instructions in section 8.
  • Choose the “Parameters” tab.

  • The details filled in on this tab are determined by the commodity code and the production method.
  • Under “Production method”, provide the required details.
    • If you use emissions data obtained via the portal for non-EU installation operators, you must select the correct production method. You can obtain this information from the producer of the goods.
    • Under “Direct Emissions qualifying parameters” and “Indirect Emissions qualifying parameters”, add the details of the specific parameters used for determining the embedded emissions.
    • If you need more information, see Commission Implementing Regulation (EU) 2023/1773: Article 3, Annex I “Information to be submitted in the CBAM reports” and section 2 “Sector-specific parameters to be included in the communication” of Annex IV.
       
  • Choose the “Emissions” tab

  • Under “Goods measure (produced)”, in the field “Net mass”, enter the net mass of the goods in tonnes.
  • Under “Type of measurement unit”, select “Tonnes” as the measurement unit.
  • Enter the details of direct embedded emissions:
    • If you use emissions data obtained via the portal for non-EU installation operators, the other fields on the tab will be filled in automatically. If you wish to use operator and installation details without emissions data, click on “Edit” in the top right corner of the tab. In that case, fill in the tab according to the instructions below. Please note that the submitter of the report remains responsible for the correctness of the report in all cases.
    • When using actual data, choose under “Direct embedded emissions”, in the field “Type of determination”, the alternative “Actual data”. 
    • In addition, under “Type of applicable reporting methodology”, choose “Commission rules” if you are reporting in accordance with the methods defined in the CBAM legislation.

The field “Specific direct embedded emissions”

  • In the field “Specific direct embedded emissions”, enter the specific embedded direct emissions. Use a dot as the decimal separator.

Field “Specific direct embedded emissions”

Enter the details of indirect embedded emissions:

  • When using actual emissions data, choose the alternative “Actual data” under “Indirect embedded emissions”, in the field “Type of determination”.
    • In the field “Source of emission factor”, choose the source of emission factor. 
      • If you use the average emission factor of the country of origin, choose “Commission based on IEA data”.
        • Under “Source of electricity”, choose “Received from the grid”.
        • In the field “Electricity consumed”, enter the amount of electricity consumed.
      • If you choose “Other” as the source of emission factor, also fill in the additional information fields “Other source indication” and “Source of emission factor value”.
        • Enter the emission factor in the field “Emission factor”.
        • Under “Source of electricity”, choose the source of electricity used for the production.
        • In the field “Electricity consumed”, enter the amount of electricity consumed.
  • Choose the “Carbon Price Due” tab
  • Provide the details regarding the carbon price due in a country of origin for the embedded emissions, if you have the details.
  • Choose the “Supplementary” tab
  • If needed, you can provide additional information under “Additional information”.
  • If needed, you can add documents under “Supporting documents” by clicking on the button “Add new”.
  • Note: If you haven’t provided actual emission data, give an account of what you have done to obtain the required data. In the field “Additional information”, provide justifications related to reported data or data gaps. Additional information may also be a description of production routes or other factors that make reporting difficult or impossible. If needed, add e.g. documents that show what you have done to obtain the emissions data under “Supporting documents”. 
  • In the top right corner, click on the button “Validate”.
    • If you receive error messages, you can find the messages and guidance on what to do on the Commission’s website in the document “CBAM Quarterly Report structure (XLS format)” on the “Error Messages Glossary” tab.
  • In the top right corner, click on the button “Save”.

4. Finish the report 

  • Choose “Header info” on the left side of the page. 

Field "Header info"

  • Choose the “Competent authority” tab
    • Under “reference number”, the number “FI000032” should be displayed If the number is missing, notify this by email to cbam@tulli.fi
  • Choose the “Signatures” tab
    • You don’t need to fill in the field “Date of signature”.
    • Enter the place of signature in the field “Place of signature”
    • Enter your name in the field “Signature (Full Name)”
    • In the field “Position of person signing”, enter your position in your organisation
    • Tick the boxes “I certify that to the…” and “I conform that the data…”

5. Submit the report 

  • Validate the details in the report by clicking on “Validate” in the top right corner
    • If you receive error messages, you can find the messages and guidance on what to do on the Commission’s website in the document “CBAM Quarterly Report structure (XLS format)” on the “Error Messages Glossary” tab.
  • You can save the report as a draft by clicking on “Save as draft”
  • When the report is ready to be submitted, submit it by clicking on “Submit”

The button “Submit”

 

6. Making subsequent modifications to the report

  • If you wish to make modifications to your report later, before the end of the modification period, select “Yes, I expect to make changes…”. Otherwise, select “No, I do not expect to make any changes…”.

Menu “Yes, I expect to make changes…”

  • You can find more information about making subsequent changes to reports on our CBAM web page under ”Obligation to report to the Commission – How”.
 

7. Proceed as follows if you have not obtained actual emissions data for CBAM reporting

When reporting emissions data for the period 1 July‒30 September 2024 and for the periods after it, you must provide the actual emissions data of the CBAM goods. The emissions data must be obtained from the producer of the goods.

If you have not obtained the required emissions data within the specified time limit, the data should be added to the report later. You should always submit a report even if you do not have any actual emissions data. On your report, you should indicate that you do not have actual emissions data. In that case, you must provide additional information about the missing emissions data. You must also prove that you have taken the necessary steps to obtain the emissions data. Read more under “Missing emissions data – what do I do and what are the possible consequences”.

The instructions below will be amended based on notifications from the Commission. We will release information on any possible changes separately.

Enter the data in the Transitional Registry as follows:

  1. Go to the “Emissions” tab.
  2. In the “Net mass” field, enter the net mass of the goods in tonnes.
  3. Under “Type of measurement unit”, select “Tonnes” as the measurement unit.
  4. Under “Direct embedded emissions”, in the field “Type of determination”, choose the alternative “Actual data not available”.
  5. In the field “Additional information”, enter the reasons for why the actual emissions data are missing.
  6. Under “Indirect embedded emissions”, in the field “Type of determination”, choose the alternative “Actual data not available”.
  7. You will receive a warning message on an orange background when you are submitting or confirming your report. The warning message does not prevent you from sending the report.

    In the “Supplementary” tab, upload the documents showing the steps you have taken to obtain the emissions data.

“Supplementary” tab

“Supplementary” tab

A warning message on an orange background

8. How to use emissions data added by the producer to the CBAM Registry via the portal for non-EU installation operators

If the producer of CBAM goods has already submitted the emissions data to the CBAM Registry via the portal for non-EU installation operators, you can add the emissions data directly to your report. Add the data as follows:

  • Make sure that you have informed the producer of the goods of your EORI number. Before you can obtain the emissions data from the Registry, the operator must first allow you access to the data.
  • Make sure that you and the operator both use the same commodity code and country of production. If these details don’t match, the system can’t find the operator or the emissions data.
  • Go to the “Installations” tab.
    • Under “Country of production”, choose the country of production.
    • Add the operator:
      • Click on “Add new” under “The company name of the installation”.
      • Click on “Search in Operators of Third Country Installations registry”. Select the correct operator from the registry and click on “OK”. The operator details are updated automatically on the page.
    • Add the installation:
      • Click on “Add new” under “Installation”.
      • Click on “Search in Operators of Third Country Installations registry”. Select the correct installation from the registry and click on “OK”. The installation details are updated automatically on the page.
  • Choose the “Parameters” tab.
    • Under “Production method”, select the production method used. You can obtain the details of the production method from the operator.
  • Choose the “Emissions” tab.
    • Under “Goods measure (produced)”, in the field “Net mass”, enter the net mass of the goods in tonnes.
    • Under “Type of measurement unit”, select “Tonnes” as the measurement unit.
    • The emissions data are filled in automatically on the tab based on the earlier choices on the previous tabs. 
    • If you wish to edit the emissions data provided by the operator, click on “Edit” in the top right corner of the tab. In that case, read the instructions in section 3. “Add the goods and their emissions data” Please note that the submitter of the report remains responsible for the correctness of the report in all cases.

If you have not obtained the required emissions data within the specified time limit, the data should be added to the report later. You should always submit a report even if you do not have any actual emissions data. On your report, you should indicate that you do not have actual emissions data. In that case, you must provide additional information about the missing emissions data. You must also prove that you have taken the necessary steps to obtain the emissions data.

If an operator submits an incorrect or incomplete report, Finnish Customs as the competent authority may initiate a correction procedure and impose a penalty on the operator. Finnish Customs follows the Commission’s guidance as its guidelines. According to the guidance, no penalty needs to be imposed if the competent authority considers that the importer has taken the necessary steps to obtain the data required for the report.

Finnish Customs will decide on possible penalties on a case-by-case basis. Finnish Customs may ask the importer to give an account of what they have done to obtain the required data. The account may include, for example, the following:

  • copies of any email correspondence where the importer requests emissions data e.g. from the seller or producer of the goods, from a possible trading partner or representative or from the operator of the installation
  • a commercial contract which indicates the length of the contract period and which may include an obligation on the producer to submit the emissions data to the importer
  • other reliable account

In the “Emissions” tab in the CBAM Transitional Registry under “Additional information,” you should enter information concerning the reported data or the incompleteness of those data. Such additional information may be, for example, documents that show what the importer has done to obtain the emissions data. Additional information may also be a description of production routes or other factors that make reporting difficult or impossible. In the “Supplementary” tab, upload the documents showing the steps you have taken to obtain the emissions data.

Guidance and an example of submitting a report are available under “Submitting a report – example”.

According to the CBAM Regulation in force, only authorised CBAM declarants are allowed to import CBAM goods into the customs territory of the Union from 1 January 2026. One of the criteria for granting the status of authorised CBAM declarant is the fulfilment of the obligations set out in the CBAM Regulation. Failure to report may therefore prevent the granting of the status.

First, request the reference number required by the system from Customs by sending email to cbam@tulli.fi. Write “CBAM reference” in the subject line, provide the company’s EORI number and the reporting period for which you wish to submit a report. When you have received the reference number from Customs, do this:

  • Log into the CBAM Transitional Registry and go to the page “My Quarterly Reports”.
  • Click on “Request delayed submission” next to the appropriate reporting period.
  • From the menu “Delayed Submission Reason”, choose “Requested by NCA” and enter the reference number you received from Customs in the field that opens.

The report must be submitted within 30 days.

Obligations from 1 January 2026

From 1 January 2026, CBAM goods can only be imported by authorised CBAM declarants. You need the authorised CBAM declarant status for importing goods, for purchasing CBAM certificates and for submitting annual reports. 

The Commission will later supplement and specify the CBAM legislation.

Apply for the authorised CBAM declarant status already during 2025. The authorisation is applied for in the CBAM Registry maintained by the EU, and it is valid throughout the EU. The link to the registry as well as instructions on how to grant mandates and log in, are available on the page CBAM Registry
 

Conditions for the authorisation

  • The applicant must be a company established in the EU territory. The applicant must have a valid EORI number.
  • In the 3 years preceding the year in which the application was submitted, the applicant must not have any
    • outstanding tax debts
    • serious or repeated infringements of customs or tax legislation
    • serious or repeated infringements of the CBAM legislation
    • history of market abuse
  • In the 5 years preceding the year in which the application was submitted, the applicant must not have any record of serious offences relating to economic activities.
  • The applicant must have the financial and operational capacity to fulfil their obligations.
    • The applicant must have an organisation appropriate to the nature and scope of the business that is suitable for the management of emission calculations. Internal audit activities must be able to prevent, detect and correct errors as well as prevent and identify illegal or unauthorised transactions. The applicant must have records of the data necessary for the calculation of emissions data, which must be kept for 5 years.

Other details and guarantee to be provided in the authorisation application

  • Attach a certificate of tax debts to the application.
  • Read more about the certificate of tax debts (vero.fi).
  • In the application, provide a declaration of honour.
    • On the “Activity details” tab of the application form, select the information under “Declaration of honour”.
    • If needed, you can provide additional information in the matter and add attachments.
  • Indicate if your company has AEO status.
    • Select the information on the “Financial and operational details” tab of the electronic application form under “AEO status information”.
    • AEO (Authorised Economic Operator) is a global partnership programme between the customs authorities and economic operators. Read more about AEO authorisations.
  • In connection with the processing of the application, Customs sends the survey “Operational readiness of the company” to the applicant. All applicants must answer the survey.
  • If the applicant’s company was founded less than 2 accounting periods ago, the company must provide a full 2-year guarantee.
    • The guarantee amount is determined by calculating the value of the CBAM certificates, which the authorised CBAM declarant should surrender based on the declared import of CBAM goods. One certificate corresponds to one tonne of embedded emissions in goods. Customs calculates the amount of guarantee required.
    • The applicant must monitor and make sure that the provided guarantee is sufficient in relation to the number of CBAM certificates required. If needed, the applicant must provide an additional guarantee.
    • The guarantee should be a bank guarantee or an account pledge provided by a financial institution operating within the EU.
      • The documents must be provided exactly in accordance with Customs’ templates, either in Finnish or in Swedish.
      • More information and examples about the guarantee templates: Guarantees

 

Report possible changes

The holder of the authorisation must immediately notify Customs if the details of the authorisation application are changed in a way that could affect the granted authorisation. Report the changes via the CBAM Registry.

The authorised CBAM declarant submits the annual declaration to the Commission’s CBAM Registry. The annual declaration must be submitted by the end of May of the year following the reporting year. The first annual declaration for imports in 2026 must be submitted by 31 May 2027.

Who can submit an annual declaration?

Importers established in the EU can submit annual declarations personally or use an indirect representative. If an indirect representative submits the declaration, the representative must be an authorised CBAM declarant.

Importers established outside the EU can’t import CBAM goods or submit annual declarations personally; instead they must use an indirect representative who is an authorised CBAM declarant.

What details are provided with the declaration?

Provide in the annual declaration

  • import goods
  • emissions data
  • carbon price possibly paid in the country of origin
  • number of returned CBAM certificates
  • necessary emissions verification reports

Declare the actual emissions of the goods. If it is not possible to declare actual emissions, provide the default values of the implementation period. Default values are always provided for electricity.

The emissions data based on actual values used in the annual declaration must be verified by accredited verifiers. If default values for the implementation period are used in the annual declaration, verification of the emissions is not required. Accredited verifiers verify and validate the greenhouse gas emissions report data.

Keep the records

The authorised CBAM declarant shall keep records of the information required to calculate the emissions. The records must be kept for five years.

The Commission checks the declarations and reports discrepancies to Customs, who clarifies the matter with the importer if needed. For example, declaring incorrect import volumes with a CBAM declaration may, at worst, result in the imposition of a penalty.

The importer must obtain chargeable emissions certificates, i.e. CBAM certificates, equivalent to the emissions of the CBAM goods they import.

Number of CBAM certificates and price

The number of certificates to be obtained is based on the embedded emissions of imported CBAM goods, with one CBAM certificate equivalent to one tonne of emissions.

The price of the CBAM certificate will reflect the ETS auction price (The European Union Emissions Trading System). The costs of CBAM certificates will increase gradually in 2026–2034 to cover the full quantity of the embedded emissions in CBAM goods.

You will receive a CBAM account when the authorisation is granted

CBAM certificates are obtained from the Commission’s central platform, which will be a part of the CBAM Registry. When the authorisation is granted, the Commission sets up a CBAM account for each authorised CBAM declarant and assigns a unique account number.

Each CBAM certificate is assigned a unique identification number. The Commission records the identification number, as well as the price and date of sale of the certificate, in the register of the authorised CBAM declarant who purchases the certificate.

Acquire the certificates by the time you submit the annual declaration

The CBAM declarant surrenders the certificates to the Commission in connection with the annual declaration.

At least 80% of the required CBAM certificates must be in the CBAM declarant's account at the end of each quarter. Outstanding certificates must be obtained within the time limit for submitting the annual declaration.

There are no restrictions on the number of certificates purchased. CBAM certificates cannot be traded.

Repurchase of CBAM certificates

Once the CBAM declarant has surrendered the required certificates in connection with the annual declaration, the Commission may, at the request of the declarant, buy back some of the unused certificates. The Commission can buy back no more than a third of the total number of emission certificates acquired the previous year.

  • The request for the repurchase of the unused certificates must be submitted by 30 June.
  • On 1 July each year, the Commission invalidates all CBAM certificates purchased in the year preceding the previous calendar year and remaining in the authorisation holder's CBAM account. The CBAM certificates are invalidated without compensation.

If the carbon price has already been paid in the country of origin, the CBAM declarant may request the Commission to reduce the number of CBAM certificates.

The CBAM Authorised Declarant must keep records from which accredited verifiers can verify embedded emissions, if necessary. In addition, the Commission and Customs must be able to check the details of the CBAM declaration based on the records.

The records must contain at least the following details:

  • name of the authorised CBAM declarant
  • CBAM account number
  • commodity code of the goods
  • quantity of each type of goods
  • country of origin of the goods
  • emissions data
    • actual emissions from the manufacture of the goods, or
    • default values

If the embedded emissions of the goods have been assessed based on the actual emissions, you need the following details:

  • identification details of the manufacturing facility
  • contact details of the operator of the facility that manufactured the goods
  • verification reports set out in Annex VI of the CBAM Regulation
  • specific embedded emissions of the goods

As verifications, attach to the records

  •  proof of the actual price paid for the carbon
    • The details contained in the documents must be verified by a person who is independent of the holder of the authorisation and the authorities of the country of origin. The documents must contain this person’s name and contact information.

The records must be kept for at least 5 years.

Proactive control refers to a control that is carried out before the authorisation is granted. This ensures that the applicant meets the conditions and requirements of the authorisation. As a rule, a proactive control includes a control related to a company’s functionality with the emphasis on examining, e.g. the company itself, its administration, organisation, accounting system and examination of internal control measures.

A subsequent control is a control that is carried out after the authorisation is granted. This ensures that the company's operations, authorisations and procedures comply with the regulations and requirements.

Other things to note

More information about the CBAM on the European Commission’s website Carbon Border Adjustment Mechanism (europa.eu), e.g. the following: 

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