CBAM Desk

CBAM importer and exporter responsibilities: who declares, who pays, and how suppliers support the data handoff

Sources checked

Since 1 January 2026 the CBAM definitive regime is in force, so the practical question is no longer whether CBAM applies to your goods. It is who does what. The short version: the EU importer — or its indirect customs representative — carries the formal legal obligations, and preparing the underlying emissions data is practical coordination the supplier can support, not a duty the Commission text places on the exporter.

Here is the split as described in the Commission's definitive-regime materials, followed by how to run the handoff in practice.

Who holds which obligation

The Commission states it directly: EU importers, or their indirect customs representatives, who import more than the single mass-based threshold of 50 tonnes of CBAM goods into the EU must apply for the status of authorised CBAM declarant.

Everything after that sits with that declarant:

  • Authorisation. The Commission encourages importers of CBAM goods, or their indirect customs representatives, to follow the instructions in the Authorisation Management Module and submit their applications for authorised CBAM declarant status. Once authorised, the declarant buys certificates from the National Competent Authority in the EU country of establishment, and requests access to the CBAM Registry through that same authority.
  • Certificates. Buy CBAM certificates from the National Competent Authority in that country. The price follows the EU ETS allowance auction price, expressed in €/tonne CO₂ — averaged quarterly in 2026, and weekly from 2027 onwards.
  • Declaration and surrender. Declare the emissions embedded in imports and surrender the corresponding number of certificates each year.
  • Deduction. Where the importer can prove a carbon price has already been paid during the production of the imported goods, the corresponding amount can be deducted.

What the exporter is actually responsible for

The definitive-regime materials reviewed here do not describe certificate-purchasing or surrender duties for the non-EU supplier; those duties are stated for the importer and its indirect customs representative. In practice, what the supplier controls is the underlying data: emissions data for the goods being shipped, and evidence of any carbon price already paid during production of those goods.

Those materials do not state how that data feeds the importer's declaration. As a practical editorial judgement, it is worth treating the request as a commercial deliverable with a lead time attached, rather than a question to answer when the customs broker asks — a suggestion about how to schedule your supplier's response, not a Commission requirement.

Which goods this covers

CBAM applies to imports of selected goods in six sectors: cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen.

One point deserves care, and it comes before the mass test. First establish that the specific product falls inside one of these six sectors: the 50-tonne threshold is a threshold for CBAM goods, so it cannot be applied to goods that are not in CBAM scope in the first place. The Commission states only that further information on sector-specific requirements is available on its dedicated sector webpage; it does not set out what those requirements are on the page reviewed here, so check product and sector applicability there before relying on the mass threshold for your case.

Running the handoff

Editorial guidance for teams that have not formalised this before:

  1. Confirm the product and sector are within CBAM scope, and identify its CN code, before applying any mass threshold. The CN code step is our own practical suggestion for working out which sector a product falls into; the Commission materials reviewed here do not prescribe it.
  2. Ask the supplier for embedded emissions data — this is our suggested practice on granularity and timing, not a Commission requirement, since the definitive-regime materials do not specify either.
  3. Ask separately for proof of any carbon price already paid during production of the imported goods. The materials reviewed here state that the importer can deduct the corresponding amount where such a price has been paid, but they do not set out a required format for that proof, so agree the presentation with your adviser and the authority concerned.
  4. Once product and sector applicability is settled, note what the 50-tonne figure is and is not: the Commission describes it as the single mass-based threshold used for authorised declarant applications concerning CBAM goods. The reviewed pages do not set out how that figure interacts with individual sectors or with a particular consignment, so the sector-specific requirements are what you need to read before treating it as the test that decides your case.
  5. Confirm whether you import in your own name or through an indirect customs representative, since the representative can hold the authorisation.
  6. Reconcile declared figures against what your supplier actually shipped, and build this into the annual surrender cycle that the rules already require.

Two timing details worth putting in a calendar

In its "What is the price of the CBAM certificate?" answer, the Commission's definitive-regime page says that certificate prices are published each calendar quarter on the Price of CBAM certificates page. The same page separately states the calculation basis: a quarterly average of EU ETS auction prices in 2026, moving to a weekly average from 2027 onwards. Note these are two different things — publication cadence versus averaging basis — and the price page itself was not among the pages archived and read for this article, so the publication cadence here rests on the definitive-regime page's wording. The reviewed materials do not state the publication cadence from 2027 onward, so only the calculation basis is confirmed here; if you model CBAM cost per shipment, note that the averaging basis changes next year.

Access to the CBAM Registry can be requested through the National Competent Authority, and the declarant portal itself is accessed via the Commission's UUM&DS portal.

This is practical editorial guidance on publicly published rules, not legal or certified advice. For your specific classification and volumes, confirm with a qualified adviser.

Official sources

Checked 2026-10-14. Only these two pages were archived and read directly; other official CBAM pages, including the certificate price page, appear in source navigation but were not themselves archived.