CBAM Reporting Requirements: What Data Do Importers Need?

The Carbon Border Adjustment Mechanism (CBAM) has moved from a reporting exercise into a real financial obligation for businesses importing carbon-intensive goods into the EU. For companies bringing in products like steel, aluminium, cement, or fertilisers, understanding exactly what data needs to be collected and why it has become essential to managing compliance costs effectively.

Where CBAM Stands Now

CBAM's transitional phase, during which importers simply reported emissions data every quarter with no financial cost attached, ended on 31 December 2025. As of 1 January 2026, CBAM entered its definitive phase. Reporting has shifted from quarterly submissions to annual declarations, and authorised importers must now purchase and surrender CBAM certificates reflecting the actual carbon emissions embedded in covered goods. The first certificate purchases begin in February 2027, with the first annual declaration, covering all goods imported in 2026 due by 30 September 2027.

This means the quality of data collected this year will directly determine certificate costs the following year.

Key Data Required for CBAM Reporting

1. Product and Customs Information

The starting point is accurate information about the imported goods. Importers need to identify the relevant CN code, country of production and quantity of CBAM goods being imported.

The CBAM Registry requires declarants to provide details such as the goods code, country of origin/production, quantity and relevant production information.

This makes accurate customs documentation particularly important. Incorrect classification or inconsistent shipment data can create problems when customs and CBAM information need to be reconciled.

For businesses managing complex international shipments, Babaji Shivram’s Customs Clearance services can support the customs side of cross-border compliance.

2. Installation and Production Details

CBAM reporting is linked not only to the product but also to where and how it was produced. Importers may need information identifying the third-country installation where the goods were manufactured, along with the relevant production method. The CBAM Registry allows non-EU installation operators to share installation and emissions data directly with CBAM declarants.

For importers sourcing from multiple suppliers or manufacturing locations, maintaining a clear link between each shipment, supplier and production installation is therefore essential.

3. Embedded Emissions Data

At the heart of CBAM reporting are the product’s embedded emissions.

Depending on the reporting approach, importers may use actual emissions data provided by the producer or applicable default values published by the European Commission. Where actual emissions are used, the relevant data must meet CBAM verification requirements.

The emissions data can include:

• Direct embedded emissions from the production process
• Relevant indirect emissions, where applicable
• Production quantity and activity data
• Emissions associated with precursor materials
• Information on the methodology used to calculate emissions

The European Commission's guidance also highlights the importance of information on production processes, monitoring methodologies and emissions calculations at the installation level.

4. Carbon Price Paid in the Country of Production

Importers should also track whether a carbon price has already been paid in the country where the goods were produced.

Under CBAM rules, where the importer can demonstrate that a carbon price has already been paid during production, the corresponding amount may be deducted when calculating the CBAM liability.

Supporting evidence should therefore be retained as part of the broader CBAM documentation trail.

Why Data Quality Affects Compliance Costs

Under the definitive phase, incomplete or missing data does not exempt an importer from the process but it simply triggers the EU's default emissions values, which are calculated less favourably than verified real-world figures. Stronger data typically translates into lower overall certificate costs.

Building a CBAM-Ready Data Process

Importers should establish a structured process for collecting and validating CBAM data from suppliers. A practical checklist can include:

• Identify CBAM-covered products and applicable CN codes.
• Map suppliers and production installations.
• Collect shipment quantities and production information.
• Request embedded emissions data from suppliers.
• Confirm the emissions calculation methodology and verification status.
• Maintain evidence of any carbon price paid.
• Reconcile CBAM data with customs and shipment records.
• Retain supporting documentation for future checks and audits.

This data flow becomes easier when customs, freight and compliance information are managed together rather than as separate processes.

Managing CBAM Compliance With the Right Partner

Collecting and managing CBAM data across multiple suppliers and shipment cycles adds a layer of complexity to standard customs clearance and freight forwarding operations. Babaji Shivram supports importers in navigating evolving EU requirements, from documentation accuracy to shipment planning, helping ensure compliance stays on track as regulations develop. More information is available through Babaji Shivram's team for businesses looking to strengthen their CBAM readiness.