Which documents do I need for CBAM?

CBAM is mostly paperwork. What you need depends on where you stand: below the 50-tonne threshold your customs documents count. As a CBAM declarant you also need minimum records, possibly producers' emission data and a multi-year retention obligation.

At a glance

Customs documents are the basis of everything: CN code, net mass, country of origin and acceptance date of the customs declaration.
If you use official default values, you need no emission data from the producer – but you pay the mark-up.
Actual emissions only with a verification report from an accredited verifier.
Keep records until the end of the fourth year after the year of the declaration – for 2026 imports until 31 December 2031.

Customs documents: the basis for threshold and declaration

Whether you reach the 50-tonne threshold and what later goes into the annual declaration follows from your customs documents. The net mass per calendar year counts; the acceptance date of the customs declaration is decisive. Suitable documents are:

customs duty notice
customs declaration or printout from the customs system
customs clearance confirmation or forwarder invoice

What matters on the document

Four items must be legible: the CN code (at least the first eight digits), the net mass in kilograms, the country of origin and the acceptance date of the customs declaration.

The most common mistake is the mass: the threshold refers to the net mass, i.e. the weight without packaging – not the gross mass from the waybill or delivery note. Likewise, the acceptance date of the customs declaration counts, not the invoice or delivery date.

If you stay below the threshold, the exemption must be stated in each customs declaration (Art. 2a(1)) – agree this with your forwarder. Keep each year's documents in order: they show that you did not exceed 50 t.

As a CBAM declarant: minimum data under Annex V

Authorised CBAM declarants must keep records detailed enough for a verifier and the authority to trace the embedded emissions and the declaration (Art. 7(5)). Annex V of the Regulation lists as minimum data:

name of the declarant and number of their account in the CBAM registry
type and quantity of each type of imported goods
country of origin
actual emissions or the default values used
the information and method used to calculate the embedded emissions

If you use actual emissions

Instead of default values you may use the producer's actual emissions – often cheaper because the mark-up does not apply. You must then also keep:

the installation where the goods were produced
the contact details of the installation operator
the verification report of an accredited verifier
the specific embedded emissions of the goods

Where the emission data comes from

Producers outside the EU can store their installation and emission data in the operator portal of the CBAM registry; declarants retrieve it there. Verifiers can register in the CBAM registry from 1 September 2026 at the earliest; the Commission expects the first verification reports for 2026 from January 2027.

So ask your suppliers early whether they can provide verified data. Without a verification report only the default values remain – with a mark-up.

Cost calculator: certificates and costs for your goods →

Evidence of a carbon price paid in the country of origin

If a carbon price has already been paid in the country of origin, it can reduce the number of certificates – with individual evidence, however, only if you use actual emissions (Art. 9). You need documentation that the price was actually paid, including any rebates or compensation and the legal basis in the third country. It must be certified by an independent person with name and contact details; plus proof of payment.

How the price paid is converted into certificates is governed by an implementing act that is still pending.

How long must I keep records?

The records including the verification report and the evidence of carbon prices must be kept until the end of the fourth year after the year in which the declaration was or should have been submitted (Art. 7(6), Art. 9(3)). For 2026 imports – declaration by 30 September 2027 – that means until 31 December 2031. The Commission can review the declaration for that long.

The CBAM annual declaration →

How CBAMfix helps

You upload your customs documents as PDF, JPG, PNG or WebP (up to 20 MB per file). The AI reads CN code, net mass, country of origin and acceptance date and points out when only the gross mass or only an invoice date is on the document. Each item only counts once you have confirmed it – the AI result is a suggestion. The documents stay filed with each import, on servers in Germany.

Frequently asked questions

Is the supplier's invoice enough as a document?

No. The information from the customs declaration counts – CN code, net mass and acceptance date. On a commercial invoice it is often missing or different. Use the customs duty notice, the customs declaration or the forwarder's clearance confirmation.

Do I need emission data from my supplier?

Not necessarily. Without verified data you use the official default values per country of origin and CN code – with a mark-up, though. You may only use actual emissions with a verification report from an accredited verifier.

How long must I keep CBAM records?

Until the end of the fourth year after the year in which the declaration was due. For 2026 imports, until 31 December 2031.

Do I have to keep documents if I stay below 50 tonnes?

CBAM then imposes no retention obligation of its own; customs retention obligations remain unaffected. It still makes sense to keep each year's customs documents in order – so you can show that you stayed below the threshold.

Stay on top of the 50-tonne threshold

CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.

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