EU CBAM confirms 30 September 2027 as the deadline for the first declaration and certificate surrender
Impact level
🟡 Consider
⚠ Risk:The original text does not list the CN codes and downstream products covered by CBAM, the free allocation arrangements, or the certificate pricing mechanism, so it is not possible to determine from this information whether specific goods are in scope.
Deadline / window:30 September 2027 [1]
What happened
On 30 September 2026, the European Commission Directorate-General for Taxation and Customs Union (TAXUD) published a recap of a CBAM webinar to help businesses prepare for the first compliance deadline on 30 September 2027. By then, they must submit their first CBAM declaration and surrender the corresponding CBAM certificates. The webinar covered the overall CBAM framework, Omnibus simplification measures, the definitive regime taking effect on 1 January 2026, the expansion to downstream products, monitoring methodologies, implementation milestones, and the declaration and certificate processes. It also mentioned recent Commission guidance for verification bodies and national accreditation bodies. [1]
Seller impact
- InferenceThe definitive regime will attach financial consequences to emissions from 1 January 2026. Importers must calculate emissions using actual or default values and hold certificates. However, the text does not specify the goods covered, how the reporting entity is identified, or the conditions for using actual values, so the overall impact is unknown. [1]
- InferenceAbout a year remains before the 30 September 2027 deadline, and suppliers need to have verifiable emissions data ready in advance. The document only mentions that guidance for verification bodies and NABs has been published; lead times, certification costs, and data availability are all unknown. [1]
Suggested action
First check whether your goods’ CN codes fall within CBAM’s current or proposed expanded scope.
Evidence that would disprove the assessment
- Assessment 1:If an implementing regulation or CN code list later published by the Commission narrows or delays the expansion to downstream products, this impact assessment should be revised downward.
- Assessment 2:If the European Commission announces a transitional exemption or an extension for filing, the assessment that data preparation is urgent will no longer hold.