Reporting during the CBAM transitional period 2023–2025

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 CBAM Legislation and 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 ”Module for non-EU installation operators (O3CI)”. 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

 

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

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, under “Useful documents” 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”
• 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 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.

• 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.
  • 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.

• 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 “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”.

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. In your report, you should indicate that you haven’t obtained actual emissions data. In that case, you must provide additional information about the missing emissions data in the report. You must also prove that you have taken the necessary steps to obtain the emissions data.

If you submit an incomplete report

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”.

Comply with the transitional obligations

From 1 January 2026, you can import more than 50 tonnes of CBAM goods into the customs territory of the EU per calendar year only if you have a valid authorised CBAM declarant status or if an application for an authorisation submitted by 31 March 2026 is pending with Customs.

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.