Regulation 2023/956: the first annual declaration for 2026 imports is due 30 September 2027. The data year is already running.
A carbon border can put a price on embedded emissions. It cannot extract those emissions from a supplier who was never asked for them.
Regulation (EU) 2023/956 establishes the Carbon Border Adjustment Mechanism. The transitional quarterly reports ran from October 2023 to December 2025. The definitive regime applies from 1 January 2026. Covered goods include iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. A mass-based threshold — 50 tonnes of CBAM goods per year, after the 2025 simplification — now sits in front of the full declarant duty.
Authorised CBAM declarants must collect the embedded emissions of the goods they import, keep evidence, and, for 2026, submit the first annual declaration and surrender the matching certificates by 30 September 2027. Certificate sales open in February 2027. From 2027, declarants must also hold certificates covering at least 50% of embedded emissions imported since the start of the year, checked each quarter.
The installation data is the operating test
Default values exist. Actual data from the producing installation is what the mechanism is built to use, and what a serious cost position depends on. That data lives with non-EU producers: production routes, direct and (where required) indirect emissions, precursors, and verification. Procurement has the vendor; sustainability has a spreadsheet; customs has the CN code. None of them, alone, is a CBAM file.
The 2026 calendar year is already the first declaration year — the same shape as a reporting obligation that uses this year’s data for next year’s filing. Every import without a usable emissions record is a line that will have to be rebuilt, defaulted or explained later.
The risk is not only a missed 30 September filing. It is reaching the declaration with figures the importer cannot trace to a supplier, an installation or a method.
Where readiness breaks
- Scope: which imported goods are CBAM goods, who is the authorised declarant, and whether the 50-tonne threshold is crossed.
- Evidence: supplier emissions data, calculation method, verification and the link from consignment to installation.
- Reporting: who calculates embedded carbon, who buys and surrenders certificates, and how the 2026 year stays reconcilable through 30 September 2027.
These are connected decisions. Treating customs, procurement and carbon accounting as separate workstreams leaves the organisation to invent a declaration from incomplete supplier replies.
What Ontzi builds
Ontzi turns the obligation into a declaration-ready operating model. We connect procurement to a request-and-validate path for supplier emissions data, calculate embedded carbon against the goods actually imported, and keep the evidence that the annual declaration and certificate surrender will need.
The immediate output is a 2026 file that can be declared. The durable value is a repeatable capability: the organisation knows which goods are in, what they emitted, who stands behind the number and how to file.
The declaration is the deadline. The operating model is what makes it defensible.
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This field note is general information, not legal advice. Thresholds, goods lists, calculation rules and certificate dates should be checked in the law applicable to each declarant.