Carbon Border Adjustment Mechanism (CBAM) brings significant changes for importers

The goods listed here which are imported from outside the EU comprise CBAM goods. The Commission requires a report on their emissions in the CBAM Transitional Registry.  

• 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:
  • Customs pages on CBAM
  • Commission's information page Carbon Border Adjustment Mechanism (europa.eu)

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.

Reporting periods and deadlines for submission of the report

 

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. 

• Guidance documents on the Commission’s webpages
• The Commission’s Webinar on how to use the Transitional Registry

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.

If you are the managing director of the company, you can submit the report yourself. Identify yourself with Suomi.fi identification in the CBAM Transitional Registry.  You are not required to have any mandates. Managing directors can also authorise other persons who can submit reports or issue further mandates.

If you have a trade name, you must grant a mandate to yourself.

For example, if you authorise an accounting firm or a consultancy firm, you must authorise an employee to do transactions, not the firm itself. Authorised employees log in to the CBAM Transitional Registry using the EORI number of the company that issued the mandate. See login instructions under “Login instructions for companies”.

What mandate is needed?

• Use the mandate “Declaring information related to the Carbon Border Adjustment Mechanism.”
• The type of mandate must be a mandate for transactions.

For instructions, see:

• Where can I see received mandates? (Suomi.fi)
• How to grant mandates
• e-Authorizations and more instructions (Suomi.fi)

Authorised parties have access to company information

Note that if you use the Suomi.fi authorisation service in electronic transactions between your company and an authorised party, for example an accountancy firm employee, the authorised party will see all your company information.

To log in, you need an EORI number.  Using the service also requires Suomi.fi identification. 

Log into the CBAM Transitional Registry through the EU Trader Portal (image below).

Make the following selections when logging in:   

• Domain: Customs
• Country: Finland
• Type of actor: Employee
• I am acting on behalf of: “The following (natural/legal) person with”
• Type of actor: Economic Operator
• Type of ID: EORI number
• ID: EORI number of the company
• Choose: Directly
• Tick the box “I give my consent…”

After this, you’re taken to the Suomi.fi identification and onwards to the transitional registry.

Guidance on how to identify yourself in the EU’s e-services

You will need these identifiers for logging into the CBAM Transitional Registry as a private individual

 

CBAM reports are submitted in the European Commission’s CBAM Transitional Registry by logging in via an e-service that is common to all EU customs administrations.

When logging into the Registry as a private individual, you will need the following:

• a valid EU Login account
• a valid EORI number
• Customs’ approval for logging into the CBAM Transitional Registry.
   

Proceed as follows:

Create an EU Login account 

• Go to the EU Login service. 
• You can change the language used in the service e.g. to English by clicking on the language menu. 
• Start creating your account by clicking on “Create an account” or by identifying yourself via your account in some other service. Although the authentication service supports the use of several social media accounts for login, Customs does not recommend using them.
• Fill in the required details, such as name and email address. In the field “E-mail language”, you can choose the language on which you wish to receive email.
• To finish off, click on “Create an account”.
• You will receive an email to your email address, with a link allowing you to set your password. Please note that you only have 24 hours to click on the link to set your password.
• The Commission’s user guide on EU Login 

Apply for an EORI number and, with the same application, request access to the CBAM Transitional Registry.

• Private individuals apply for an EORI number using a form. You can find more information and the forms on the web page the EORI-number.
• In the form, provide your EU Login identifier.
• In the form, tick the box “I have imported or am importing CBAM goods, and I require access to the CBAM transitional registry. A copy of my proof of identification is enclosed with this registration form.”
• Send the form to Customs by email. Enclose a scanned copy of an official proof of identity (passport or identity card). Copy the page or side with your photo.
• Send the form to the email address indicated in the form. When you send personal data or other confidential information to Customs, we recommend that you use secure email. Read more about secure email  

Before logging in

To log in, you need an EORI number and an EU Login identifier. Check the instructions under “Identifiers needed by private individuals”.

Logging in

Log into the CBAM Transitional Registry through the EU Trader Portal (image below).

Make the following selections when logging in: 

• Domain: Carbon Border Adjustment Mechanism
• Country: Finland
• Type of actor: Economic Operator
• Type of ID: EORI number
• ID: Enter your EORI number here
• I am acting on behalf of: Myself
• Tick the box “I give my consent to request my Identity Profile information…”
• Click on Submit

 

• On the page that opens, under “Enter your e-mail…”, enter your EU Login identifier or the email address for which the identifier was created.
• Click on the blue button “Next”
• On the next page, enter your EU Login password in the field “Password”
• Choose your verification method
  • The commission recommends two-step identification with a QR code.
• Click on “Sign in”.
• Scan the QR code using the EU Login Mobile App
• Type the one-time password sent to your mobile phone in the “Code generated by your app” field
• Click on “Sign in”.

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

• Transitional CBAM Registry user manual for Declarants on the Commission’s website
• CBAM Webinar: Transitional Registry – Traders’ Info session

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 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.

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

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 third country installation operators registry”
• Select the name of the installation operator and click on “Ok”
• Click on “Create” in the top right corner

• 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.

• 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 
  
• 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 “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.

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

• 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 or, if you have added the operator details in advance, click on “Search in third country installation operators registry”.
• Choose the operator and click on “OK”. The operator details will be automatically displayed in the fields below. 
• Add the installation details by clicking on “Add new” under “Installation”.
• You can add the details manually or if you have added the installation details in advance, click on “Search in installation registry”.
• From the list that opens, choose the installation that produced the goods and click on “OK”. The installation details will be automatically displayed in the fields below
• 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:
  • 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.

• If you are reporting emissions data obtained using other methods, choose the alternative “Oher methods” in the field “Type of applicable reporting methodology”. In that case, you should enter additional information on the reporting method in the field “Additional information”.

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

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 “Parameters” tab
• 
  • On this tab, the fields to be filled in vary based on the goods selected.
  • Under “Production method”, provide the required details of the production routes
  • Under “Direct Emissions qualifying parameters” and “Indirect Emissions qualifying parameters”, add information on specific parameters 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”, section 2 “Sector-specific parameters to be included in the communication” of Annex IV
• 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”. The field is mandatory if you don’t provide operator details or installation details.
• 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”.

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.

From 2026, the authorised CBAM declarant status is required for imports of CBAM goods. The authorisation is also required for purchasing CBAM certificates and for submitting annual declarations. The authorisation is valid throughout the EU and it can be applied for from the beginning of 2025 via the Commission’s service. From 1 January 2026, Customs will prevent imports of CBAM goods by importers that are not authorised CBAM declarants.

On order for an importer to be granted the authorised CBAM declarant status, the following conditions must be fulfilled:

• During the five years preceding the application, the applicant has not been involved in a serious infringement or in repeated infringements of customs legislation, taxation rules, market abuse rules or the CBAM Regulation and delegated and implementing acts adopted under the CBAM Regulation. 
• The applicant has no record of serious criminal offences relating to its economic activity.
• The applicant must have financial and operational capacity to fulfil its obligations under the CBAM Regulation.
• The applicant is established in the Member State where the application is submitted.
• The applicant must have an EORI number.

(Article 17 of the CBAM Regulation (EU) 2023/956)

If the importer appoints an indirect customs representative who agrees to act as a CBAM declarant on behalf of the importer, the indirect customs representative must apply for the authorised CBAM declarant status. The indirect customs representative must also apply for the authorisation if the importer is not established in the EU.

The importer must purchase chargeable emissions certificates, i.e. CBAM certificates. 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.

The certificates will be purchased on the Commission’s central platform, and they will be automatically registered in a CBAM account, which the Commission establishes for each declarant.  At the end of each quarter, the authorised CBAM declarant must have at least 80% of the required CBAM certificates available on its account. There are no restrictions on the number of certificates purchased. Outstanding certificates must be obtained within the time limit for submitting the annual CBAM declaration.

The required number of CBAM certificates must be surrendered in connection with the annual declaration. When the CBAM declarant has surrendered the required certificates in connection with the annual declaration, the Commission can, at the declarant’s request, repurchase no more than one third of the of the total number of CBAM certificates purchased during the previous year. 

The Commission will later specify the details related to chargeable CBAM certificates. On the Commission’s CBAM webpage, you can find legislative documents as well as up-to-date guidance, such as “CBAM – Questions and Answers” under FAQ.

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. The Commission will later specify the details related to the calculation, verification and default values regarding emissions.

Authorised CBAM declarants submit annual declarations 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 must be submitted for 2026 imports by 31 May 2027. The required number of CBAM certificates must be surrendered in connection with the annual declaration. The required emissions verification reports must also be attached to the 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 submit annual declarations personally; instead they must use an indirect representative who is an authorised CBAM declarant.

The declaration shall contain the following information: the imported goods, the emissions in the goods, the carbon price possibly paid in the country of origin, the number of CBAM certificates to be surrendered as well as the required verification reports.

The CBAM declarant shall keep records of the information required to calculate the emissions, and those records shall be kept for five years.

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

• Frequently asked questions: “CBAM - Questions and Answers” under FAQ.
• Guidance documents for both importers and operators outside the EU under Guidance
• The Commission’s “CBAM communication template for installations” as well as related examples and an instructional video under Guidance.
• Webinars and learning modules by product category as well as for all CBAM operators under Sectoral information.

• Regulation (EU) 2023/956 of the European Parliament and of the Council establishing a carbon border adjustment mechanism
• Implementing Regulation (EU) 2023/1773 regarding the CBAM transitional period
• Act on implementing the Carbon Border Adjustment Mechanism of the European Union (1288/2023) (available in Finnish and Swedish)
• Act on the amendment of section 2 of the Act on Customs Administration 1289/2023 (available in Finnish and Swedish)