First CBAM certificate surrender deadline: 30 September 2027

CBAM Compliance Checklist

Six steps every EU importer of carbon-intensive goods must complete before the definitive regime bites. Built by the customs compliance team at CustomsPlus®. Automated by MyCustomsInfo®.

The six things you need in place

Step 01

Identify your CBAM-covered imports

Map every import against CBAM product categories: iron & steel, aluminium, cement, fertilisers, electricity, and hydrogen. Include both direct imports and goods processed through intermediaries.

Step 02

Collect embedded carbon data from suppliers

Request actual embedded emissions data from each non-EU supplier. Where supplier data is unavailable, default values from EU implementing regulations apply — but they carry a cost premium you need to quantify.

Step 03

Assess your Ireland exposure

If you import CBAM-covered goods through Ireland into the EU single market, you face both EU CBAM obligations and potential UK CBAM requirements from January 2027. Dual-regime exposure must be mapped now.

Dual-regime risk — requires immediate attention
Step 04

Establish your CBAM declarant registration

Register as an authorised CBAM declarant with the relevant national competent authority. Without registration, you cannot purchase or surrender CBAM certificates.

Step 05

Build your certificate purchase strategy

CBAM certificates are priced weekly at the EU ETS carbon price. Model your certificate obligation based on import volumes and embedded emissions to budget accurately.

Step 06

Prepare for 30 September 2027

The first annual CBAM declaration — covering calendar year 2026 imports — is due 30 September 2027. Build your reporting infrastructure and internal processes now, not in Q3 2027.

CustomsPlus® methodology. MyCustomsInfo® automation.

CustomsPlus® is the customs consultancy that developed the compliance methodology behind this checklist. Every step reflects real regulatory obligations under the EU CBAM Regulation (2023/956) and the UK Finance Act 2025.

MyCustomsInfo® is the platform that automates that methodology. It tracks your CBAM-covered imports, manages embedded carbon data from suppliers, generates quarterly reports, and calculates your certificate surrender obligation — so your compliance team can focus on decisions, not data collection.

Download the full CBAM checklist

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US Regulatory Notice. MyCustomsInfo® is an independent compliance auditor. It does not conduct customs business as defined under 19 U.S.C. §1641. The specific tariff classification to be applied to any entry of merchandise is to be determined by a licensed Customhouse broker. MyCustomsInfo® output does not constitute entry preparation, classification advice, or customs broker services. Preparation and filing of Post-Entry Amendments, Post-Summary Corrections, protests, and drawback claims must be performed by a licensed customs broker. US broker records are held in US AWS regions in compliance with 19 C.F.R. §111.23. Primary authority: CBP HQ H272798 (January 2017). Supporting authority: CBP HQ H350722 (January 2026).

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