The EU Carbon Border Adjustment Mechanism(CBAM) is no longer a future regulation—it's active, and non-compliance carries financial consequences. If you manufacture cement, steel, aluminum, fertilizers, hydrogen, or electricity outside the EU and export these goods to European markets, understanding CBAM deadlines is critical to maintaining market access.
From January 2026 onwards, the CBAM transitions from its transitional reporting phase to the definitive phase, where financial obligations begin. Missing deadlines can result in penalties ranging from €10 to €50 per tonne of unreported emissions—costs that quickly add up for high-volume exporters.
This guide outlines the key deadlines manufacturers must know, the reporting requirements at each stage, and actionable steps to ensure compliance.
During this phase, EU importers of CBAM goods must submit quarterly reports on embedded emissions. As a manufacturer, you are responsible for providing accurate emissions data to your EU importers.
Key characteristics:
From 2026, EU importers must purchase and surrender CBAM certificates corresponding to the embedded emissions of imported goods. Manufacturers who fail to provide verified emissions data will be subject to default emission values—typically higher than actual emissions, resulting in higher costs for your EU customers.
Key changes:
|
Deadline |
Action Required |
Who is Responsible |
Consequence of Missing |
|
31 January 2025 |
Q4 2024 Report (Oct-Dec) |
EU Importer (requires your data) |
Penalty: €10-€50/tonne |
|
30 April 2025 |
Q1 2025 Report (Jan-Mar) |
EU Importer (requires your data) |
Penalty: €10-€50/tonne |
|
31 July 2025 |
Q2 2025 Report (Apr-Jun) |
EU Importer (requires your data) |
Penalty: €10-€50/tonne |
|
31 October 2025 |
Q3 2025 Report (Jul-Sep) |
EU Importer (requires your data) |
Penalty: €10-€50/tonne |
|
31 December 2025 |
End of Transitional Phase |
All Parties |
Transition to financial obligations |
|
31 May 2026 |
First CBAM Declaration (2025 imports) |
EU Importer (requires verified data) |
Certificate purchase required |
|
Ongoing from 2026 |
Annual Verification of Emissions Data |
Manufacturer (via accredited verifier) |
Default values applied if unverified |
1. Monitor Embedded Emissions (Direct + Indirect)
You must track:
Accepted methodologies:
2. Communicate Data to EU Importers Quarterly
Your EU customers (importers) must submit quarterly reports. You should provide them with:
Recommended tool: Use the European Commission's voluntary communication template(Excel-based) to standardize data exchange.
3. Prepare for Verification (Starting 2026)
From 2026, third-party verificationbecomes mandatory. Accredited verifiers will assess your emissions monitoring methodology and validate your reported data.
Steps to prepare:
If your EU importer fails to submit a quarterly report due to missing data from you, they face penalties of €10 to €50 per tonne of unreported goods. While the penalty is levied on the importer, repeated non-compliance can damage your business relationship and may result in importers seeking alternative suppliers.
From 2026, if you do not provide verified emissions data, your EU customers will be assigned default emission values. These are set at the 90th percentile of global emissions intensity for each product category—meaning they are significantly higher than the actual emissions of most installations.
Example:
For a manufacturer exporting 10,000 tonnes annually, this results in €800,000 in avoidable costs.
Starting in January 2025, manufacturers can register on the CBAM Operator Portal to:
Benefits: ✅ Centralized data management
✅ Restricted access to sensitive information (only authorities see
full details)
✅ Streamlined communication with EU importers
How to register: Visit the European Commission CBAM Portal and follow the operator registration process.
By 31 January 2025:
By 31 July 2025:
By 31 December 2025:
By 31 May 2026:
Navigating CBAM deadlines and compliance requirements can be complex, especially for manufacturers managing multiple export markets. WOLQE CBAM offers:
✅ CBAM Readiness Assessment – Evaluate your current emissions
monitoring and identify gaps
✅ Verification Support – Connect with accredited verifiers and
prepare documentation
✅ Data Management Solutions – Implement systems to track and
report emissions efficiently
✅ Quarterly Reporting Assistance – Ensure timely and accurate
data delivery to EU importers
Ready to ensure compliance? Run the CBAM Checker to assess your obligations or Request a Free Consultation with our CBAM experts.
For Manufacturers:
For Importers:
This article is for informational purposes only and does not constitute legal, tax, or regulatory advice. CBAM regulations are subject to updates and amendments by the European Commission. Manufacturers should consult the official EU CBAM Regulation (EU) 2023/956 and Implementing Regulation (EU) 2023/1773, as well as seek guidance from qualified legal and compliance advisors