EU & UK CBAM compliance from a single platform
CBAM is in its definitive regime. Default values are published. Certificate surrender starts September 2027.
CustomsPlus® has been managing EU CBAM quarterly reporting since the transitional period began in October 2023. We are now operating under the definitive regime — applying the country-specific and product-specific default values from Commission Implementing Regulation (EU) 2025/2621, tracking the progressive markup schedule, and preparing clients for their first certificate surrender in September 2027. If you are importing CBAM-covered goods into the EU or preparing for the UK CBAM (effective January 2027), our European experience is directly relevant.
CBAM in plain terms
The EU Carbon Border Adjustment Mechanism (Regulation 2023/956) requires importers of goods in covered sectors to account for the embedded carbon produced in manufacturing their imports. The transitional period ran from October 2023 to December 2025, during which importers submitted quarterly reports. From 1 January 2026, the definitive CBAM regime is in force — importers must now purchase and surrender CBAM certificates to cover the embedded emissions in their goods.
The 2026 default values. Commission Implementing Regulation (EU) 2025/2621 (published 31 December 2025) sets out the definitive default values that apply where actual supplier emissions data is not available. These values are a fundamental change from the transitional period: they are now country-specific and product-specific, replacing the world-average defaults used previously. The regulation provides three sets — direct emissions (Annex I), indirect emissions (Annex II), and electricity (Annex III). A progressive markup is applied: 10% in 2026, 20% in 2027, and 30% from 2028 onwards (fertilisers carry a reduced 1% markup due to supply-chain data complexity).
UK CBAM. The UK is implementing its own Carbon Border Adjustment Mechanism under the Finance Act 2025, effective from January 2027. It covers the same core sectors as the EU regime. Companies importing CBAM-covered goods into both the EU and the UK will need to manage parallel compliance programmes with distinct registration, reporting, and certificate frameworks. Our experience operating under the EU CBAM since day one positions us to prepare UK importers before their obligations begin.
Covered sectors under both regimes: cement, iron and steel, aluminium, fertilisers, electricity, hydrogen, and (under expanded EU scope) ceramics and glass.
How MyCustomsInfo® manages your CBAM obligations
Quarterly report preparation
We extract the relevant import data from your declaration history, match it against your supplier-provided embedded carbon values, and prepare your quarterly CBAM report in the format required by the EU CBAM registry. You review and submit. We do the work.
Embedded carbon data management — including 2026 default values
CBAM compliance depends on accurate embedded carbon data from your suppliers. Where supplier data is unavailable, we apply the definitive country-specific and product-specific default values published in Commission Implementing Regulation (EU) 2025/2621 — including the markup schedule (10% in 2026, 20% in 2027, 30% from 2028). MyCustomsInfo® flags every gap so you can pursue actual data from suppliers over time.
Certificate surrender preparation (2027 onwards)
Under the definitive CBAM regime, importers must surrender CBAM certificates equal to the embedded carbon in their imports. We track your certificate obligation as it accrues, factor in the applicable default-value markups, and give you the figures you need to purchase the right number of certificates at the right time.
UK CBAM readiness (Finance Act 2025)
The UK CBAM takes effect January 2027. If you import CBAM-covered goods into the UK, you have a limited window to establish your compliance infrastructure. Our hands-on experience operating under the EU CBAM since October 2023 means we already understand the data workflows, supplier engagement patterns, and default-value pitfalls your UK compliance programme will face. MyCustomsInfo® supports both EU and UK CBAM reporting from a single platform.
CBAM key dates
EU CBAM transitional period begins. Quarterly reports required.
First quarterly CBAM report due (Q4 2023 data).
Commission Implementing Regulation (EU) 2025/2621 published — definitive country-specific and product-specific CBAM default values.
EU CBAM definitive regime begins. Default-value markup of 10% applies in 2026.
Final transitional quarterly CBAM report due (Q4 2025 data).
UK CBAM takes effect (Finance Act 2025). Default-value markup rises to 20% for EU CBAM.
First EU CBAM certificate surrender deadline (annual declaration covering calendar year 2026).
EU CBAM default-value markup rises to 30% (and remains at 30% thereafter).
What happens if you miss a CBAM deadline?
Failure to submit a quarterly CBAM report results in a financial penalty calculated per tonne of CO2 equivalent embedded in the unreported goods. The EU Commission has confirmed penalty rates between €10 and €50 per tonne, depending on the duration and nature of the non-compliance. For a mid-sized steel importer, that can represent a significant liability.
More significantly, non-compliance with CBAM reporting obligations will be a factor in customs risk profiling. Businesses with a record of CBAM non-compliance are more likely to receive a post-clearance check across their full import programme.