If you were unable to meet the deadline for submitting a CBAM report, you may request a delayed submission. To do this, click on the ‘Request delayed submission’ button next to the relevant quarter for which you wish to submit the CBAM report retrospectively in the ‘My quarterly reports’ tab in the CBAM transition tab.

Please note the following instructions for using the ‘Request by NCA’ button in the ‘My Quarterly Reports’ application for CBAM declarants in Germany:

• You may use this button not only when you have been explicitly reminded by DEHSt to submit your CBAM report.
• Please also use this button separately to request a late submission of your CBAM report. You will need to provide a reference number.
• You may create your own reference number. It should be made up of the relevant quarter and your EORI number. Example: Q1-2024/EORI number
• There is no need to create a new enquiry to DEHSt in the CBAM transitional registry.
• You have 30 days to submit your report after having applied for the ‘Request delayed submission’ function.

Further information including click instructions, can be found in the European Commission's document ‘Guidance for declarants – Request Delayed Submission’, which can be found on the Commission's website.

Guidance for CBAM Declarants on the Request Delayed Submission

Amendments to a CBAM report that has already been submitted may be made by the reporting declarant in accordance with Article 9(1) of Commission Implementing Regulation (EU) 2023/1773 of 17/08/2023 laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and of the Council with regard to the reporting obligations applicable during the transitional period for the purposes of the Carbon Border Adjustment Mechanism (hereinafter referred to as the CBAM Implementing Regulation on reporting obligations during the transitional period). Such amendments may be submitted by the reporting declarant up to two months after the end of the respective reporting quarter – that means no later than one month after the submission deadline for the CBAM reports.

This may be the case, for example, if more detailed data on embedded emissions becomes available to the importer after the reporting deadline. Please note the submission deadline. If the amended report is not submitted within the two-month deadline, no more amended report can be submitted. You must then submit an application for late submission and follow the steps described above.

In addition, CBAM reports may also be corrected after the deadline within one year of the end of the quarter in question on the basis of a reasoned request, provided this has been authorised by the competent authority, in accordance with Article 9(3) of the CBAM Implementing Regulation for the reporting obligations in the transitional period.

If you wish to correct a report after the deadline, please send us via the request function of the CBAM transitional registry.

• the ID of the relevant report,
• the reason for the amendment requested and
• the specific corrections envisaged

The registry will then inform you of the next steps.

You can create the CBAM report either directly in the CBAM transitional registry by entering your data into the relevant fields. Alternatively, you can compile your data into an XML file and import it into the CBAM transitional registry.

Since January 2025, there has been a newmodule in the CBAM registry, module for non-EU installation operators (or Operators of Third Country Installations Portal or O3CI Portal). The module enables operators from third countries to upload their installation and emissions data in a standardised format and share it with reporting declarants. This reduces the effort required for data acquisition on the declarants’ side and for data transmission on the operators’ side. Reporting declarants can include this information in the CBAM reports. Declarants can retrieve the information provided by third-country operators in the transitional registry by selecting the ‘Search in the registry for third-country operators’ function in the ‘Operators’ tab when submitting emissions.

Since 01/08/2024, CBAM declarants have been required to determine and report the actual emissions for each import of CBAM goods with the exception of electricity, in accordance with the calculation methods set out in Article 4(1) or (2) of the CBAM Implementing Regulation for reporting obligations during the transitional period.

If CBAM declarants do not have data on actual emissions from suppliers and/or manufacturers for their imported CBAM goods, they are not exempt from their reporting obligations. Instead, declarants must demonstrate that they have taken all necessary and reasonable steps to determine the emissions and explain why they had been unable to obtain the necessary data on the CBAM goods from suppliers and/or manufacturers.

Please note the paragraph below with the description of the screenshots. Source: German Emissions Trading Authority (DEHSt) at the German Environment Agency

• Please note the paragraph below with the description of the screenshots
• Please select the new option ‘Actual data not available’ in the mandatory field ‘Direct embedded emissions – type of determination’ circled in red at the top. Selecting this option automatically inserts the figure zero (0) in the following field ‘Specific (direct) embedded emissions.’
• Please proceed correspondingly in the mandatory field ‘Indirect embedded emissions – type of determination’ as circled in red below.
• In addition, briefly explain in the mandatory field ‘Further information’ circled in green, confirming that you have taken reasonable steps to report the actual emissions.
• Finally, please click on the ‘Additional’ tab circled in blue to document the unsuccessful efforts and steps taken to obtain data from suppliers and/or manufacturers. Please note carefully that if no documents have been uploaded under ‘Additional’, the following note will appear:
  • Warning message: For imports as from 1 July 2024, reporting declarants are required to report actual emissions for each CBAM good imported into the EU. If the option "Actual data not available" is chosen, the CBAM report will be considered incorrect/incomplete. Reporting declarants must undertake all possible efforts to obtain actual emission data from their supplier(s) or producer(s) of CBAM goods. Where reporting declarants eventually fail to get data on actual emissions, this option shall be used. In addition, please follow these steps: 1. Use the "Additional Information" field to provide justifications on why the actual emissions data is missing. 2. In the tab "Supplementary", upload supporting documents attesting unsuccessful efforts and steps taken to obtain data from suppliers and/or producers.

Standard values may still be used for the import of electrical power.

CBAM reports submitted in accordance with the previous requirements do not need to be adjusted retrospectively, unless the European Commission exercises their right to request additional information.

To date, CBAM reports frequently contain very high import tonnages that do not appear to align with trade data and trading patterns. In order to prevent potential errors that may lead to negative

financial consequences because of unrealistically high obligations to surrender CBAM certificates in the definitive regime, please note the following:

• Quantities of goods must be specified in tonnes (not kilograms) in the CBAM transitional registry.
• Thousand and decimal separators must be used in accordance with English conventions, that means “1,000” is understood as one thousand and “1.5” as one and a half. Please ensure that the point (FULL STOP) is understood as a decimal separator.
• Please make sure that the quantities (in tonnes) specified in the CBAM reports correspond to the quantities (in tonnes) declared in the customs declarations for the relevant quarter. Should the convention in the German version of the Registry change, we will inform you accordingly in our newsletter.

Common errors in the preparation of reports that may result in the portal refusing acceptance of a report, together with guidance on how to fix errors can be found under the ‘Error Message Glossary‘ tab in the CBAM Quarterly Report structure (XLS format) file.

CBAM Quarterly Report structure (XLS format)

During the transitional period, the quarterly CBAM reports need not be verified. In the definitive regime, starting in 2026, authorised CBAM declarants will be required to submit annual CBAM declarations, which must be verified in case actual emission values are used,

For more information, please visit our website

CBAM Definitive Regime from 2026

Verifiers and verification (page currently under construction).

DEHSt has the discretionary power to decide when or whether to initiate a correction procedure. If the CBAM declarant has not used actual emissions data in their CBAM report to calculate embedded emissions, the DEHSt will exercise its discretionary power and consider whether:

• declarants have comprehensibly demonstrated that they have taken all reasonable steps to report the actual emissions and that any further investigation of the actual data would have required a disproportionately high effort and/or
• have demonstrated that they have done everything possible to report actual emissions and, furthermore,
• whether there are further discrepancies in the submitted report.

With regard to the proportionality of the effort involved, DEHSt will in particular take into account the significance of the underlying CO2 emissions caused by CBAM imports. Notwithstanding DEHSt's discretionary powers, the Commission may, pursuant to Article 35(4) of the CBAM Regulation, request that DEHSt demand additional information from CBAM declarants to supplement or correct an incomplete or incorrect CBAM report.

DEHSt has already initiated correction procedures due to failure to submit a CBAM report. Should the declarant fail to comply with a request, or fail to submit a CBAM report, DEHSt will automatically initiate the correction procedure

Legal source

CBAM Regulation (EU) 2023/956

Implementing Regulation (EU) 2023/1773 on the Transitional Period