CBAM Deadlines: 2026 Imports, 2027 Declarations
Last reviewed: 4 August 2026 · Author: Kadim Rammahi, Founder, AllMarketZones
The key CBAM deadlines for 2027 are that the provisions governing the sale of CBAM certificates apply from 1 February 2027 (Article 36(2), point (d), Regulation (EU) 2023/956) and the first annual CBAM declaration, covering 2026 imports, is due by 30 September 2027 (Article 6(1)). The core definitive-regime provisions apply from 1 January 2026 (Article 36(2), point (b)), so obligations accrue on imports made throughout 2026.
These dates matter because the CBAM timetable spreads across two calendar years: imports and authorisation duties fall in 2026, while certificate purchases and the declaration fall in 2027. Failure to surrender the required certificates attracts the penalty under Article 26(1) — identical to the EUR 100 per tonne excess emissions penalty in Article 16(3) of Directive 2003/87/EC, increased under Article 16(4) of that Directive — with the surrender obligation still standing (Article 26(3)). This guide sets out each date, its governing provision, and who it applies to.
AllMarketZones provides a fixed-fee CBAM Scope Assessment: a written determination of scope and obligations. We do not provide authorised declarant representation, emissions verification, or binding customs classification advice; where those are required we coordinate accredited partners. For context, see our CBAM compliance guide.
The CBAM deadline table for 2026 and 2027
The sequence of CBAM deadlines runs from the start of the core definitive-regime provisions on 1 January 2026 to the first annual declaration on 30 September 2027. The table below lists each date, the obligation attached to it, and its provision in Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 ("Omnibus I").
| Date | Obligation | Provision |
|---|---|---|
| 1 January 2026 | Core definitive-regime provisions apply, including the Article 2a threshold, the declaration and certificate provisions (Articles 6 to 9, 21, 22(1)) and penalties (Articles 23 to 27) | Article 36(2), point (b) |
| 1 January 2027 | Article 22(2) certificate-holding provision applies | Article 36(2), point (c) |
| 1 February 2027 | Sale of CBAM certificates begins; purchases relate back to 2026 imports | Articles 20 and 36(2), point (d) |
| 30 September 2027 | First annual CBAM declaration due, for the year 2026, with surrender of corresponding certificates | Articles 6(1) and 22(1) |
When is the first CBAM declaration due?
The first annual CBAM declaration is due by 30 September 2027 and covers imports made during the 2026 calendar year: Article 6(1) of Regulation (EU) 2023/956, as amended by Omnibus I, requires each authorised CBAM declarant to submit the declaration in the CBAM registry "by 30 September of each year, and for the first time in 2027 for the year 2026". The declaration reports the embedded emissions of covered goods imported in 2026 (Article 6(2)), and the declarant surrenders certificates corresponding to those emissions (Article 22(1)). See our guide to becoming an authorised CBAM declarant.
What happens on 1 January 2026
On 1 January 2026 the core definitive-regime provisions of Regulation (EU) 2023/956 apply (Article 36(2), point (b)), and obligations begin to accrue on covered imports. From that date the Article 2a de minimis governs who is exempt: an importer whose Annex I goods do not cumulatively exceed 50 tonnes of net mass in the calendar year (Article 2a(1); Annex VII, point 1) is exempted, while an importer exceeding the threshold is subject to all obligations for that year's imports (Article 2a(2)) and one expecting to exceed it is required to apply for authorisation (Article 5(1b)). The transitional period, during which importer obligations were limited to reporting, ran from 1 October 2023 until 31 December 2025 (Article 32) — see our 50-tonne CBAM threshold guide.
Certificate sales and pricing from February 2027
The provisions governing the sale of CBAM certificates apply from 1 February 2027 (Article 36(2), point (d), Regulation (EU) 2023/956). Certificates purchased in 2027 relate back to 2026 imports, since obligations accrue from 1 January 2026 while sales start the following year. For embedded emissions declared in respect of the year 2026, the price of certificates is calculated as the quarterly average of the closing prices of EU ETS allowances on the auction platform for the quarter of importation of the goods (Article 21(1a), inserted by Omnibus I); the general rule for later years is the weekly average of closing prices (Article 21(1)). Declarants surrender, by 30 September, the number of certificates corresponding to their declared embedded emissions (Article 22(1)).
An importer brings 250 tonnes of aluminium bars (CN 7604, listed in Annex I) into the EU across 2026, with embedded emissions assessed at 1,500 tonnes of CO2. Having expected to exceed the 50-tonne threshold, it applied for authorisation (Article 5(1b)). From 1 February 2027 it can buy CBAM certificates (Article 36(2), point (d)), priced for 2026 emissions on the quarterly-average basis (Article 21(1a)). By 30 September 2027 it files its first annual CBAM declaration for the 2026 imports (Article 6(1)) and surrenders 1,500 certificates (Article 22(1)). If it fails to surrender 100 of them, the Article 26(1) penalty applies per missing certificate — EUR 100 per tonne of CO2 equivalent under Article 16(3) of Directive 2003/87/EC, as increased under Article 16(4) — and the 100 certificates must still be surrendered (Article 26(3)).
The belief: Because certificate sales and the declaration fall in 2027, there is nothing to do in 2026.
The reality: Obligations accrue on imports made from 1 January 2026 (Article 36(2), point (b)), and an importer expecting to exceed the 50-tonne threshold is required to apply for authorisation (Article 5(1b)). A person other than an authorised declarant who introduces goods without complying with the Regulation is liable to a penalty of three to five times the standard Article 26(1) penalty (Article 26(2)).
What changed from the transitional phase
During the transitional period from 1 October 2023 until 31 December 2025, the obligations of importers were limited to reporting (Article 32, Regulation (EU) 2023/956). From 1 January 2026 the financial provisions apply (Article 36(2), point (b)): obligations accrue on imports and are settled through the annual declaration and certificate surrender in 2027 (Articles 6(1) and 22(1)). Omnibus I inserted the single mass-based de minimis of 50 tonnes net mass per importer per calendar year (Article 2a(1); Annex VII, point 1) and set the declaration deadline at 30 September, first applying in 2027 for the year 2026 (Article 6(1)). The Article 2a exemption does not apply to electricity and hydrogen (Article 2a(4)).
How the two-year timetable affects planning
The CBAM timetable spans two calendar years, so importers plan across both 2026 and 2027 rather than treating them separately. During 2026, the practical tasks are securing authorisation where the threshold will be exceeded (Article 5(1) and (1b)) and collecting embedded-emissions data from suppliers, since the declaration must state the embedded emissions of the year's imports (Article 6(2)). During 2027, the tasks shift to purchasing certificates once Article 20 applies from 1 February (Article 36(2), point (d)) and filing the annual declaration by 30 September (Article 6(1)). Because certificates purchased in 2027 cover 2026 imports, cash-flow planning should anticipate the certificate cost falling in 2027 for goods already imported.
Who each deadline applies to
The 1 January 2026 provisions and the Article 2a threshold concern any importer of Annex I goods into the EU customs territory (Articles 2(1) and 2a(1)). The 1 February 2027 start of certificate sales and the 30 September 2027 declaration concern authorised CBAM declarants (Articles 20, 6(1) and 22(1)). A business without EU establishment meets these obligations through an indirect customs representative, who obtains the declarant status where the importer is not established in a Member State (Article 5(2)).
Penalties for missing CBAM deadlines
An authorised declarant that fails to surrender the required certificates by 30 September is liable to the Article 26(1) penalty — identical to the excess emissions penalty in Article 16(3) of Directive 2003/87/EC, which is EUR 100 for each tonne of carbon dioxide equivalent, increased in accordance with the European index of consumer prices under Article 16(4) — for each certificate not surrendered, and the surrender obligation is not removed by payment (Article 26(3)). A person other than an authorised declarant who introduces goods without complying with the Regulation is liable to three to five times that penalty (Article 26(2)). The mechanism is documented by the European Commission — CBAM. In Germany, the competent authority is the DEHSt — see our guide to CBAM compliance in Germany.
Frequently asked questions
When is the first CBAM declaration due?
By 30 September 2027, for the year 2026: Article 6(1) of Regulation (EU) 2023/956, as amended by Omnibus I, requires the CBAM declaration in the CBAM registry by 30 September of each year, for the first time in 2027 for the year 2026. Certificates corresponding to the declared embedded emissions are surrendered under Article 22(1).
When does the definitive CBAM regime start?
The core definitive-regime provisions — including Articles 2a, 6 to 9, 21, 22(1) and 23 to 27 — apply from 1 January 2026 (Article 36(2), point (b), Regulation (EU) 2023/956). The transitional period, limited to reporting obligations, ran from 1 October 2023 until 31 December 2025 (Article 32).
When do CBAM certificate sales begin?
The provisions governing the sale of CBAM certificates (Article 20(1), (3), (4) and (5)) apply from 1 February 2027 (Article 36(2), point (d), Regulation (EU) 2023/956). For emissions declared in respect of 2026, the certificate price is the quarterly average of EU ETS auction closing prices for the quarter of importation (Article 21(1a)).
How is the CBAM certificate price set?
As the general rule, the price is the average of the closing prices of EU ETS allowances on the auction platform for each calendar week (Article 21(1), Regulation (EU) 2023/956). By derogation, for embedded emissions declared in respect of the year 2026 the price is the quarterly average of closing prices for the quarter of importation (Article 21(1a)).
What is the penalty for missing a CBAM deadline?
Under Article 26(1) of Regulation (EU) 2023/956, failing to surrender the required certificates attracts a penalty identical to the excess emissions penalty in Article 16(3) of Directive 2003/87/EC — EUR 100 per tonne of CO2 equivalent, increased under Article 16(4) — per certificate not surrendered. Payment does not remove the surrender obligation (Article 26(3)), and unauthorised importing attracts three to five times that penalty (Article 26(2)).
Do CBAM obligations apply to imports made in 2026 or 2027?
Obligations accrue on imports made from 1 January 2026 (Article 36(2), point (b), Regulation (EU) 2023/956), even though certificate sales start on 1 February 2027 and the first declaration is due 30 September 2027. The first annual declaration reports the 2026 imports (Article 6(1)).
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About this guidance. Prepared from Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 ("Omnibus I"), Commission implementing regulations, and published guidance from the German Emissions Trading Authority (DEHSt). Primary sources: European Commission — CBAM and DEHSt. Author: Kadim Rammahi, Founder, AllMarketZones — full bio.
Limitations. AllMarketZones provides cross-border marketplace expansion and trade governance advisory, including a fixed-fee CBAM Scope Assessment. We do not provide authorised declarant representation, emissions verification, or binding customs classification advice; where those are required, we coordinate accredited partners.