Short answer: a producer outside the EU does not file anything with the EU. The annual CBAM declaration is submitted by the authorised CBAM declarant in the EU (2023/956 Art. 6(1)). What you prepare is your installation's embedded emissions per product: the operator's emissions report and its summary (2025/2547 Art. 10).
An EU buyer who asks for "your CBAM report" needs the number that goes into its own declaration. The Carbon Border Adjustment Mechanism (CBAM) sets rules on how that number is worked out at the plant. This article follows Regulation (EU) 2023/956 and Implementing Regulation (EU) 2025/2547 step by step. The information was read from the sources on 13 October 2026.
What does a buyer mean by "CBAM report"?
Two parties have two different jobs. The authorised CBAM declarant submits a CBAM declaration by 30 September each year for the preceding calendar year, for the first time in 2027 for 2026 (2023/956 Art. 6(1)). It states the quantity of goods imported, the total embedded emissions and the number of certificates to be surrendered (Art. 6(2)).
Where embedded emissions are calculated from actual emissions, the operator of the installation prepares an emissions report and a summary of it, in English (2025/2547 Art. 10(1), 10(4)). An "operator" is any person that operates or controls an installation in a third country (2023/956 Art. 3(31)).
Which products are in scope?
Scope is set by CN code. The list is in Annex I: cement, electricity, fertilisers, iron and steel, aluminium and hydrogen (2023/956 Annex I). Check the code of every product you sell to the EU against that list. For the codes, see CBAM product scope and CN codes.
How do you define the installation and its production processes?
The calculation is done per installation (2023/956 Art. 3(30)). Within it, the operator identifies the production process of goods that share the same functional unit (2025/2547 Art. 4(1)). For most goods that unit is the tonnes produced under the same CN code (Art. 4(2)). For certain cement codes it is the clinker contained, for certain fertilisers the nitrogen contained, for electricity the kWh (Art. 4(3)-(5)).
Where the same goods are made through different production routes, a single production process covers all of them (Art. 4(6)). Which operations count is set by the system boundaries, defined per aggregated goods category in Annex I (2025/2547 Art. 3(1)).
What data do you have to monitor?
The operator implements a monitoring plan with at least the elements in point A.5 of Annex II, in English (2025/2547 Art. 5(5), 5(6)). The reporting period is the calendar year: 2026 for goods imported in 2026 (Art. 7(1)).
| Data | Used for | Source |
|---|---|---|
| Fuel and raw material consumption | Direct emissions ("source streams", "activity data"). | 2025/2547 Art. 1(8), 1(12), 5(1) |
| Heat flows | Monitored where heat is involved in production. | 2025/2547 Art. 5(2) |
| Electricity consumption | Indirect emissions. | 2025/2547 Art. 5(4) |
| Precursors | Input materials that are themselves on the Annex I list. | 2025/2547 Art. 1(7), 5(3) |
| Production quantity | Activity level: goods produced in the period. | 2025/2547 Art. 1(2) |
What is the difference between direct and indirect emissions?
Direct emissions come from the production processes, including the heating and cooling they consume (2023/956 Art. 3(21)). Indirect emissions come from producing the electricity those processes consume (Art. 3(34)).
For goods listed in Annex II (iron and steel, aluminium, hydrogen and electricity) only direct emissions are taken into account (2023/956 Art. 7(1)). For goods outside Annex II, such as cement and fertilisers, the system boundaries also cover indirect emissions (2025/2547 Art. 3(2)).
How are specific embedded emissions per product calculated?
This is the number your buyer needs: the embedded emissions of one tonne of goods, in tonnes of CO2e (2023/956 Annex IV, point 1(c)). It takes two steps.
- Attribution: find the part of the installation's emissions caused by the production process of the goods (2023/956 Annex IV, point 2; 2025/2547 Art. 6, Annex III).
- Division: divide it by the quantity of goods produced in the period (Annex IV, point 2).
For "complex goods", made with precursors, the embedded emissions of the precursors consumed are added (2023/956 Annex IV, point 3). The precursor's value comes from the installation that produced it. Actual emissions for your own processes can be combined with default values for precursors (2025/2547 Art. 15). For the formulas, see how embedded emissions are calculated.
How does the report reach the buyer, and what is the communication template?
Two documents are prepared: the operator's emissions report and its summary. Their minimum content is listed in points 1.1 and 1.2 of Annex IV to 2025/2547. The summary identifies the operator and the installation and gives, for each product, the specific direct embedded emissions, the share for which default values were used and the specific embedded free allocation (Annex IV, point 1.2). It protects commercially sensitive detail: the full report goes to the verifier, and the summary is made accessible to declarants (2025/2547 recital 17).
An operator may ask the Commission to register its installation in the CBAM registry, for five years (2023/956 Art. 10(1), 10(3)). A registered operator may disclose the verified information to a declarant (2023/956 Art. 10(7)).
The Commission publishes an Excel file, the CBAM communication template for installations. The latest version is 2.1.1, dated 13 December 2024, built on the transitional period rules. As of 1 October 2026 the Commission's page had no version updated for the definitive period. If you use the template, check separately that your report carries the minimum information in Annex IV.
Is verification mandatory, and who does it?
Where embedded emissions are determined from actual emissions, the total declared must be verified by an accredited verifier (2023/956 Art. 8(1)). Installation visits by the verifier are mandatory unless specific criteria for waiving them are met (2023/956 Annex VI, point 1(c)). Who prepares which document is covered in CBAM document for exporters.
What happens if the producer provides no data?
Embedded emissions are determined from actual emissions or by reference to default values (2023/956 Art. 7(2)). With no producer data, the declarant is left with default values. A default value is the average emission intensity of the exporting country for that product, increased by a mark-up (2023/956 Annex IV, point 4.1). Under Implementing Regulation (EU) 2025/2621 it is 10% for 2026, 20% for 2027 and 30% from 2028. For fertilisers it is 1%.
Default values need no verification, because that requirement is tied to actual emissions (Art. 8(1)). But the number of certificates follows the embedded emissions (Art. 6(2)(c)), so a marked-up default value feeds into your buyer's cost.
What has changed since the transitional period ended?
| Topic | Transitional period (1 October 2023 to 31 December 2025) | Definitive period (since 2026) |
|---|---|---|
| The importer's task | Reporting only: a quarterly CBAM report, within one month of quarter end (2023/956 Art. 32, 35(1)). | A yearly CBAM declaration and surrender of certificates by 30 September (Art. 6(1), 22(1)). |
| Calculation method | Implementing Regulation (EU) 2023/1773 (2025/2547 recital 2). | Implementing Regulation (EU) 2025/2547. |
| Verification | The Commission's template marks verifier fields as not required. | Mandatory where actual emissions are declared (Art. 8(1)). |
Because the new method applies from 2026, no period before 2026 can serve as the reporting period (2025/2547 recital 24).
The Registamp CBAM module runs these steps from your installation records: it calculates embedded emissions per product and prepares the summary for your buyer. See the CBAM module page.
This article is general information, not legal advice. For your own case, refer to the text of the Regulation and, where needed, to a specialist.
Sources
- Regulation (EU) 2023/956, CBAM (consolidated text of 20 October 2025): eur-lex.europa.eu/eli/reg/2023/956/oj
- Implementing Regulation (EU) 2025/2547, methods for calculating embedded emissions: eur-lex.europa.eu/eli/reg_impl/2025/2547/oj
- Implementing Regulation (EU) 2025/2621, default values: eur-lex.europa.eu/eli/reg_impl/2025/2621/oj
- European Commission, CBAM communication template page: taxation-customs.ec.europa.eu