Insights / CBAM
CBAM Declaration and Certificate Surrender Deadline for 2026 Imports
By when must the CBAM declaration be submitted and certificates surrendered for goods imported in 2026?
By 30 September 2027. The annual CBAM declaration and the surrender of CBAM certificates both fall on 30 September of the year after the imports (Articles 6(1) and 22(1) of Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083).
What the act says
- Article 6(1): The authorised CBAM declarant submits the CBAM declaration for the previous calendar year by 30 September.
- Article 22(1): Certificates matching the declared embedded emissions are surrendered by the same 30 September.
- Article 20(1): Certificates go on sale from 1 February 2027, so they can be bought before the first surrender.
- 15 February 2027: This date in Implementing Regulation (EU) 2025/2549 applies only where an authorisation is revoked with effect within 2026. It is not the general deadline.
What to do
- Put 30 September 2027 in the compliance calendar for everything imported in 2026.
- Collect embedded emissions data from suppliers during 2026, not after it.
- Plan certificate purchases from 1 February 2027.
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- Regulation (EU) 2025/2083 amending the CBAM Regulation (CELEX 32025R2083)
Last checked against the act text on 2026-10-20. For information only, not legal advice.