The first annual CBAM declaration is due 30 September 2027 and covers steel imported into the EU during 2026, the opening year of the definitive regime. Certificates surrendered with that declaration are priced off the EU ETS, which averaged EUR 75.36 per tonne of CO2e in Q1 2026, with a 2.5 percent payable share.
The first CBAM declaration is due 30 September 2027
The first annual CBAM declaration falls due on 30 September 2027 and covers steel imported into the European Union during the 2026 calendar year. The definitive CBAM regime has been live since 1 January 2026, so every consignment of covered iron and steel crossing the EU border in 2026 builds up an embedded emissions obligation that is settled in that first annual filing. The declaration is submitted by an authorized CBAM declarant, states the embedded emissions in the year’s imports, and surrenders CBAM certificates against the payable share. Importers below the de-minimis threshold of 50 tonnes per year stay outside the obligation.
The CBAM timeline at a glance
The obligation for steel is framed by these dates:
- 1 August 2024: CBAM reporting requires actual rather than estimated emissions data.
- 1 January 2026: the definitive regime goes live for six product groups including iron and steel; 2026 is the first certificate year, with a payable share of 2.5 percent of embedded emissions.
- 30 September 2027: the first annual CBAM declaration is due, covering 2026 imports.
- 2034: the payable share reaches 100 percent of embedded emissions.
What the 2027 deadline means for steel supply chains
The first declaration is priced gently but sets the data discipline for every year after it. Certificates surrendered with the 2027 filing are priced off the EU ETS, which averaged EUR 75.36 per tonne of CO2e in Q1 2026, applied to a payable share of only 2.5 percent of embedded emissions; the same machinery then scales to 100 percent by 2034, which is where the real exposure sits, as set out in the cost outlook for steel exporters. Emissions figures in the declaration must rest on actual installation data, required since 1 August 2024, with verification carried out by an accredited verifier. Steel exporters supplying EU customers can prepare well before the deadline: map covered CN codes in the CBAM guide, assemble installation level emissions data for the 2026 import year, and engage a CBAM consulting service to calculate embedded emissions, prepare CBAM reports and manage certificate exposure ahead of the September 2027 filing.
Sources: Regulation (EU) 2023/956 · European Commission CBAM