CBAM Transitional Phase 2025: Exactly What You Must Report, When, and to Whom
CBAM transitional reporting requires importers to submit embedded emissions data quarterly to the EU CBAM Transitional Registry. The data requirement is specific: you need the quantity imported, the country of origin, the specific production facility's direct embedded emissions in tonnes of CO₂ equivalent per tonne of product, and any carbon price already paid at origin. Getting this data from non-EU suppliers is the practical challenge.
- Who Must Register and Report Under CBAM
- The Quarterly Report: What Data It Must Contain
- Quarterly Deadlines: The Reporting Calendar
- Getting Embedded Emissions Data from Suppliers: The Hard Part
- Penalties for Non-Compliance During the Transitional Phase
Who Must Register and Report Under CBAM#
Any EU-established importer who declared CBAM goods at EU customs during a calendar quarter must register as a CBAM declarant and submit a quarterly report. This includes businesses importing steel, aluminium, cement, fertilisers, electricity, or hydrogen under the specific CN codes listed in Annex I of CBAM Regulation 2023/956. Non-EU businesses (indirect customs representatives or customs agents) may file CBAM reports on behalf of importers, but the legal responsibility — including any penalties — sits with the EU-established importer. Registration is through the EU CBAM Transitional Registry, operated by the European Commission, using the importer's EORI number. Member states have designated national competent authorities to enforce CBAM — in most cases, the national customs authority.
The Quarterly Report: What Data It Must Contain#
Each quarterly CBAM report must cover all imports of CBAM goods in that quarter and include, for each batch of goods: the total quantity imported in tonnes, the country of origin, the type of goods (CN code), the direct embedded emissions in tonnes of CO₂ equivalent per tonne of goods, the indirect embedded emissions (for applicable goods categories including electricity, aluminium, and steel) per tonne of goods, and the carbon price paid in the country of origin per tonne of goods that can offset the CBAM obligation. For the transitional phase, the Commission has allowed importers to use estimated or default values for embedded emissions if actual supplier data is unavailable — but from 2026, only verified actual data will be accepted. Default values are set conservatively high to incentivise obtaining real data.
CBAM transitional reports are due quarterly, covering the imports of the preceding three-month period.
Quarterly Deadlines: The Reporting Calendar#
CBAM transitional reports are due quarterly, covering the imports of the preceding three-month period. The deadlines are: 31 January (for October-December), 30 April (for January-March), 31 July (for April-June), and 31 October (for July-September). These are firm deadlines — there is no formal grace period provision in the regulation. The first report, covering October-December 2023, was due 31 January 2024. Some member states provided informal guidance allowing late submissions in the early quarters given the newness of the system, but this administrative tolerance should not be relied upon. Importers with complex supply chains involving multiple CBAM goods categories and multiple countries of origin should build reporting workflows well in advance of each deadline.
Data-backed guides on AI, eCommerce, and SME strategy — straight to your inbox.
Getting Embedded Emissions Data from Suppliers: The Hard Part#
The most difficult operational challenge of CBAM transitional reporting is obtaining reliable embedded emissions data from non-EU suppliers. Many manufacturers in Turkey, India, China, Ukraine, and other major steel and aluminium exporting countries have not historically measured or reported product-level carbon footprints. The specific data required — direct embedded emissions from the production process in tonnes of CO₂e per tonne of product, by individual production facility — is highly granular. Supplier questionnaires are the standard tool: importers send structured data requests asking suppliers to report their production emissions using the methodology set out in Commission Implementing Regulation 2023/1773. Where suppliers cannot provide facility-specific data, default values published by the Commission must be used — these are set at the 90th percentile of global emissions intensity, making them significantly higher than the actual emissions of efficient producers.
Penalties for Non-Compliance During the Transitional Phase#
Penalties for CBAM transitional phase non-compliance are set by each EU member state under national law, as the regulation requires but does not prescribe the exact penalty structure. The Commission's guidance indicates expected penalties in the range of €10-50 per tonne of unreported or incorrectly reported CO₂ equivalent. For an importer bringing in 10,000 tonnes of steel per year — not large by industry standards — the penalty exposure at €50 per tonne could reach €500,000. Beyond financial penalties, non-compliance risks designation as a non-compliant CBAM declarant, which may affect the importer's relationship with customs authorities more broadly. AskBiz sends automated reminders for each CBAM quarterly deadline and tracks which of your imports require reporting, so you can maintain compliance without manual calendar management.
- CBAM transitional reporting requires importers to submit embedded emissions data quarterly to the EU CBAM Transitional Registry.
- The data requirement is specific: you need the quantity imported, the country of origin, the specific production facility's direct embedded emissions in tonnes of CO₂ equivalent per tonne of product, and any carbon price already paid at origin.
- Getting this data from non-EU suppliers is the practical challenge.
People also ask
When are CBAM quarterly reports due?
CBAM transitional quarterly reports are due on 31 January (Q4), 30 April (Q1), 31 July (Q2), and 31 October (Q3). Each report covers all CBAM goods imported in the preceding three-month period. Reports are submitted through the EU CBAM Transitional Registry using your EORI number. AskBiz sends deadline reminders and pre-populates available import data to help you prepare each quarterly submission accurately and on time.
What happens if my supplier cannot provide embedded emissions data?
If your non-EU supplier cannot provide facility-specific embedded emissions data using the Commission's calculation methodology, you can use default values published by the European Commission in Implementing Regulation 2023/1773. These defaults are set at the 90th percentile of global emissions intensity for each product category — meaning they are higher than the actual emissions of most efficient producers. Using defaults increases your reported emissions and, from 2026, your CBAM certificate cost. Obtaining actual supplier data is therefore strongly in your commercial interest. AskBiz provides supplier questionnaire templates aligned to Commission methodology.
Do CBAM reports cover indirect emissions or only direct production emissions?
CBAM covers both direct embedded emissions (from the production process itself) and indirect embedded emissions (from electricity used in production) for certain goods categories. Electricity, aluminium, and some steel products require indirect emissions reporting. Direct emissions are the fuel and process emissions from the manufacturing facility; indirect emissions relate to the carbon intensity of the electricity grid powering the facility. For most cement and fertiliser imports, only direct emissions are in scope for CBAM. The distinction matters for your data collection — you need to ask suppliers for both production fuel consumption data and electricity consumption data where indirect emissions apply.
Our team combines expertise in data analytics, SME strategy, and AI tools to produce practical guides that help founders and operators make better business decisions.
Never Miss a CBAM Quarterly Deadline
AskBiz tracks your CBAM-liable imports, sends deadline reminders, and helps you manage supplier data requests — so your quarterly reports are filed accurately and on time. Start free.
Connects to Shopify, Xero, Amazon, QuickBooks, Stripe & more in minutes