CBAM 2026: an eight-point readiness checklist for importers

The Carbon Border Adjustment Mechanism moved past its transitional phase in January 2026. Quarterly reports ended with 2025. The liability now accrues on 2026 imports: certificate sales open in February 2027, and the first annual declaration and surrender are due by 30 September 2027. Importers below the 50 tonne annual threshold are exempt.

The eight things you need

1. An authorised CBAM declarant registered in the CBAM registry.
2. Verified embedded emissions data from every non-EU supplier, per installation.
3. A methodology fallback for suppliers who cannot provide primary data yet.
4. Purchase records of CBAM certificates matched to import volumes.
5. Evidence of carbon prices already paid in the country of origin (to net off).
6. Internal reconciliation between customs declarations and CBAM filings.
7. A verifier on retainer for the annual verification cycle.
8. A commercial clause pushing supplier data obligations into your contracts.

Use our CBAM affected products guide as a working document with your customs broker.