CBAM Reports
A practical breakdown of the CBAM report — its structure, required data fields, XML submission format, and how it differs from the annual CBAM declaration used under the definitive regime.
A practical breakdown of the CBAM report — its structure, required data fields, XML submission format, and how it differs from the annual CBAM declaration used under the definitive regime.
A CBAM report is the formal document an importer (or their indirect customs representative) submits to the European Commission to disclose the embedded emissions of goods brought into the EU under the Carbon Border Adjustment Mechanism. The term technically refers to the quarterly filings used during the 2023–2025 transitional period, though it's commonly used more loosely to describe any CBAM submission, including the annual declaration now used under the definitive regime.
This guide focuses on what actually goes into a CBAM report: its structure, the specific data fields it requires, the format it's submitted in, and the practical differences between the original quarterly report and today's annual declaration.
These two terms get used interchangeably a lot, but they refer to different filings from different phases of CBAM:
If you're preparing a filing for 2026 imports or later, you're working with a declaration, not the original quarterly report format — though the underlying data (quantities, embedded emissions, carbon price paid) is conceptually similar.
Regardless of which version you're preparing, a CBAM filing is built around the same core data structure:
Total quantity of Cbam goods imported — broken down by product type and CN code, for the reporting period (quarter or year).
Total embedded emissions — direct emissions from production, and, where applicable, indirect emissions from the electricity used in production.
Carbon price already paid in the country of origin — this reduces the CBAM liability, since the mechanism is designed to top up to EU-equivalent carbon pricing, not stack an additional charge on top of an already-paid carbon cost.
Installation and production route details — which facility produced the goods and via which manufacturing process, since embedded emissions vary significantly by production route even within the same product category.
The original quarterly CBAM report during the transitional period was notably granular: its structure includes 226 individual data fields per imported product type, covering everything from goods measures and direct/indirect emissions to production parameters and carbon-price documentation. The definitive-regime annual declaration builds on this same underlying data model but adds the certificate calculation and verification components on top.
Beyond the emissions data itself, every CBAM report needs several administrative fields to be valid:
Report issue date — the date the report is submitted.
Draft report ID — a unique identifier the declarant assigns when creating and saving the report.
Report ID — a separate unique identifier assigned by the CBAM system once the report is formally submitted.
Reporting period — the specific quarter (for transitional reports) or calendar year (for declarations) being covered.
Reporting declarant / importer / representative details, entered under separate tabs in the registry interface.
The Commission allows two ways to prepare and submit CBAM report data:
Direct online entry into the CBAM Registry (or, historically, the Transitional Registry) interface, filling in each field manually.
XML upload, using a structured file that matches the Commission's published XSD schema for the CBAM quarterly report structure. This is the practical option for companies with many product lines or suppliers, since it allows the report to be generated from an internal spreadsheet or supply-chain data system rather than entered field by field.
The Commission has published sample ZIP files, an XLS reference file specifying which fields are mandatory versus optional, and separate sample files for importers and for representatives, all designed to help declarants validate their XML structure before submission. Getting this file structure right matters — declarants are required to report using the XML reporting template when doing bulk or automated submissions, and must also attach a reference to any exporter/supplier report used to support the declared figures.
Based on the patterns seen across transitional-period guidance and national customs communications, a few issues come up repeatedly:
Missing or mismatched CN codes — a product classified under the wrong CN code either falls outside CBAM scope incorrectly, or gets reported under the wrong product category with the wrong emissions methodology.
Incomplete installation data — reports that don't properly identify the production facility or route make it harder to substantiate reported emissions figures, particularly during verification under the definitive regime.
Default values used without documentation of the effort to obtain actual data — while default values are a legitimate fallback, undocumented reliance on them can raise questions during review, especially now that verification is mandatory.
XML structure errors — files that don't validate against the published XSD schema will be rejected outright, regardless of whether the underlying data is accurate.
Confirm which CN codes apply to your imported products and cross-check them against Annex I of Regulation (EU) 2023/956.
Identify the production installation and route for each product line — this determines which emissions calculation methodology applies.
Request actual emissions data from suppliers first, falling back to Commission default values only where genuine data can't be obtained, and keep a record of that outreach.
Calculate direct emissions for all sectors, and indirect emissions specifically for cement and fertilisers, following the Commission's Guidance Document 3 methodology.
Document any carbon price already paid in the country of origin, since this offsets your CBAM liability.
Choose your submission method — manual entry for a small number of product lines, or XML upload validated against the current XSD schema for larger, multi-supplier operations.
Arrange third-party verification (for definitive-regime declarations) well ahead of the 30 September deadline, since accredited verifiers can have their own scheduling lead times, especially during peak filing season.
For a broader explanation of how the report fits into the full compliance cycle — including registry access, authorisation, and certificates — see our companion guides on CBAM reporting and the CBAM Registry. For background on the wider Carbon Border Adjustment Mechanism, this CBAM overview offers additional supplementary context, though it should be cross-checked against the Commission's own guidance for anything decision-critical.
Is a CBAM report the same document as a CBAM declaration? Not technically — "report" refers to the quarterly transitional-period filings (2023–2025), while "declaration" refers to the annual filing used from 2026 onward. In practice, the terms are often used loosely to mean any CBAM submission.
Can I amend a CBAM report after submitting it? During the transitional period, reports could generally be amended for several months after the original deadline, with further correction requests possible afterward. Under the definitive regime, corrections are still possible but are complicated by the verification requirement, so accuracy at first submission matters more.
Do I need special software to prepare the XML file? Not necessarily — the Commission provides the XSD schema and sample files needed to build a compliant XML file, but many companies use dedicated CBAM or carbon-accounting software to automate generation and validation, particularly when reporting across many suppliers and product lines.
What happens if my supplier won't share emissions data? You can fall back on Commission default values, but since these are set conservatively, this typically increases the certificates you'll need to surrender. Documenting a genuine attempt to obtain supplier data is still worthwhile, as the Commission has indicated this effort is considered relevant, even where it doesn't produce usable figures.
A CBAM report — whether the transitional quarterly filing or today's annual declaration — is only as reliable as the data behind it: accurate CN code classification, clear production-route identification, and, wherever possible, real supplier emissions data rather than conservative defaults. Understanding the report's actual field structure and submission format, not just the regulatory headlines, is what separates a smooth filing from a last-minute scramble before the deadline.