The hard part of CBAM is rarely the concept. It is keeping track of which obligation falls due when — especially after the Omnibus simplification (Regulation (EU) 2025/2083) moved several dates and thresholds in late 2025. This page lays out the timeline as it stands now, so you can map your own import flows against it.
The two phases, briefly
CBAM ran as a transitional period from 1 October 2023 to 31 December 2025 — reporting only, with quarterly reports and no payment. That phase is over.
The definitive period began on 1 January 2026. From this date, importers of covered goods above the threshold take on financial obligations: they must be authorised, must hold CBAM certificates against the emissions embedded in their imports, and must declare and surrender those certificates each year.
Are you even in scope? The 50-tonne threshold
The Omnibus package replaced the old €150-per-consignment exemption with a single mass-based de minimis threshold of 50 tonnes of CBAM goods imported per importer (per EORI number) per calendar year.
- If your total annual imports of covered goods stay at or below 50 tonnes, you are exempt from CBAM reporting, authorisation, and certificate obligations.
- Important caveat: electricity and hydrogen are excluded from this exemption — there is no de minimis for those two.
- Once you cross 50 tonnes at any point in the year, obligations apply to all your relevant imports from 1 January of that year, not just the volume above the threshold.
The timeline that matters
| When | What happens |
|---|---|
| From 1 Jan 2026 | Definitive period live. Customs check for authorised-declarant status at release for free circulation. |
| By 31 Mar 2026 | Deadline to apply for authorised CBAM declarant status and keep importing while your application is assessed. |
| End of each quarter, 2026 on | Hold CBAM certificates covering at least 50% of embedded emissions of goods imported since 1 January that year (reduced from 80% by the Omnibus). |
| From 1 Feb 2027 | Sales of CBAM certificates open (postponed from 2026). Declarants buy certificates for 2026 and later emissions. |
| By 30 Sep 2027 | Submit your first annual CBAM declaration (for 2026 imports) and surrender the matching certificates. |
| 30 Sep each year after | Recurring annual declaration and surrender deadline. |
Authorised CBAM declarant status
Only an authorised CBAM declarant can import covered goods above the threshold. You apply through the CBAM Registry in your Member State of establishment (the application section opened on 31 March 2025). Applications submitted by 31 March 2026 let you continue importing while the authority assesses you. Without authorisation, customs can block release of your goods for free circulation.
Why the documents have to start now, not in 2027
The declaration deadline feels distant, but the evidence behind it accrues all through 2026. Your 30 September 2027 declaration has to reconcile every covered shipment imported during 2026 with the embedded-emissions data behind it. If supplier data, CN-code decisions, and source documents are not captured as shipments happen, you are reconstructing a year of imports from scattered inboxes at the deadline — exactly when it is hardest.
A clean shipment register and evidence archive built during the year is what turns the 2027 declaration from a scramble into a review. See also the breakdown by sector for steel importers and aluminium importers.