The 2026 CBAM import file for the first 2027 declaration

What this import file is

The import file is the working record that sits between customs data, supplier replies, emissions evidence, and the annual CBAM declaration workflow. It is where an importer turns one year of 2026 imports into a reviewable set of rows, assumptions, and open questions.

The file should answer four practical questions before the 2027 declaration work begins: which imported goods are in current CBAM scope, how much net mass was imported by the relevant legal entity, which supplier and installation data exists, and which evidence gaps still need human review.

• Keep it internal and preparation-focused: the import file is not a CBAM Registry submission, XML file, declaration, or authority response.
• Use it as a CBAM checklist for import lines: scope, threshold, supplier data, actual/default emissions basis, certificate-price context, and unresolved issues.
• Date the sources used for every regulatory assumption so later reviewers can see whether a row reflects current adopted rules or an older snapshot.

Why 2026 records matter before the 2027 declaration

The definitive period began on 1 January 2026, but the first annual CBAM declaration covers 2026 imports and is due by 30 September 2027 under Regulation (EU) 2025/2083. That gap creates a false sense of time. The reporting year is already producing the records the first declaration will depend on.

Waiting until 2027 turns every missing supplier reply, CN-code doubt, data-basis question, and evidence reference into a deadline problem. Building the import file during 2026 turns the work into a sequence: identify covered goods, collect supplier data, attach evidence references, and escalate only the gaps that deserve expert attention.

Start with the importer, legal entity, and threshold context

The first tab or section should identify the importer or legal entity the file is about, the import year, the relevant EORI or internal entity reference, the owner of the work, and the review date. This prevents mixed-entity extracts from making the 50-tonne threshold or annual totals look cleaner than they are.

Regulation (EU) 2025/2083 introduced a 50-tonne de-minimis threshold for cumulative net mass of CBAM goods per importer/legal entity per calendar year, with electricity and hydrogen excluded from that exemption. The import file should therefore keep net mass by legal entity and preserve the sector context for each row.

• Record the legal entity or EORI context for the file rather than merging several entities into one unlabelled workbook.
• Keep electricity and hydrogen visibly separate from threshold thinking because the exemption does not apply to those sectors.
• Use the threshold status as a review input, not as a standalone conclusion about authorisation or obligations.

Build the goods register before the emissions register

The goods register is the skeleton of the file. Each line should identify the import period, customs reference or internal shipment reference, CN code, commercial description, origin country, supplier, net mass, and the CBAM sector if the code is in current Annex I scope.

Do not start with emissions numbers. Start with whether the product is actually in scope under the adopted Annex I list. A clean goods register also separates current-scope rows from proposal watch items, such as downstream products that appear only in a Commission proposal and not in the adopted list.

• CN code used for customs declaration, not only the supplier's product name.
• Goods description and internal SKU or purchasing reference where available.
• Origin country and supplier name, kept separate from the importer legal entity.
• Net mass in tonnes and the period or import date the row belongs to.
• Scope status: current Annex I match, outside current scope, or proposal watch item requiring separate review.

Add supplier and installation data status

Once the covered goods are identified, the import file should track whether supplier data has been requested, received, reviewed, or still missing. The most useful status is not a vague yes/no flag. It separates the supplier reply, the emissions values, the data basis, the supporting evidence, and the follow-up owner.

Supplier-reported data is not the same thing as verified actual emissions. For definitive-period planning, a row can be useful even while it remains unreviewed, but the file should label that status plainly so later reviewers do not mistake a supplier email for a completed verification path.

• Supplier contact and production installation, where known.
• Production route or process named by the supplier.
• Reporting period covered by the emissions figures.
• Actual values, official default values, or mixed/unknown basis.
• Direct and indirect embedded-emissions values, where provided.
• Precursor-data status, especially where production inputs affect the calculation basis.

Keep evidence references separate from conclusions

The file should not try to turn every document into a verdict. It should list the evidence reference, what it appears to support, who provided it, when it was received, and what still needs review. That keeps the workflow useful without implying that CBAM Pulse or a spreadsheet has approved the data.

A practical evidence row can be simple: evidence type, source, date received, goods or supplier row linked, claim supported, open issue, owner, and next step. This is enough to turn scattered PDFs, emails, supplier portals, and adviser notes into a review queue.

• Evidence type: supplier calculation, monitoring note, emissions report, independent check, carbon-price statement, or internal note.
• Reference: file name, email subject, link, or document identifier; do not rely on memory.
• Status: requested, received, reviewed internally, sent to adviser, or unresolved.
• Open question: missing installation, unclear production route, missing precursor detail, conflicting mass, old reporting period, or source-date mismatch.

Add current assumptions without freezing them forever

The import file can include planning assumptions such as the current official CBAM certificate price, the adopted free-allocation adjustment schedule, the derived CBAM-covered share, threshold context, and default-value source references. Each assumption needs a source and date beside it.

Do not paste a price, threshold, or factor into the file without a source stamp. Certificate prices are published by the European Commission, and later quarters can change the planning picture. The point of the file is traceability, not a permanent number copied from last quarter's screenshot.

• Current certificate price source and publication date.
• Import year and the adopted CBAM factor/free-allocation adjustment context for that year.
• Default-value source or actual-emissions basis for each relevant goods row.
• Any origin-country carbon price information the supplier provided, labelled as provided data rather than a deduction decision.

Use a gap log as the operating layer

The import file becomes valuable when it turns missing information into owned actions. A gap log should be attached to the goods and supplier rows rather than kept in a separate todo list. Otherwise the same issue gets rediscovered by procurement, customs, finance, and advisers in different language.

Good gap labels are concrete: missing CN confirmation, missing net mass, supplier data not requested, supplier data requested but not received, actual/default basis unclear, precursor data missing, emissions period not aligned, carbon-price statement missing, evidence reference missing, or adviser review needed.

A workable monthly cadence

A lightweight cadence beats a heroic annual cleanup. Importers can review new customs extracts monthly, add or update goods rows, check threshold movement, send supplier requests for new covered goods, and mark evidence references as they arrive. The annual 2027 work then becomes a review of an existing file rather than a reconstruction exercise.

For businesses with few CBAM lines, the cadence can be simpler: monthly or quarterly goods update, supplier follow-up after each new product or supplier, and a pre-declaration review window in 2027. The key is that every gap has a date, owner, and next action.

• Monthly: import-line update, scope check, threshold movement, new supplier-request triggers.
• Quarterly: supplier follow-up, evidence-reference cleanup, assumptions source-date review.
• Before 2027 declaration work: reconcile final 2026 mass, supplier-status coverage, actual/default data basis, and unresolved expert-review questions.

What not to put in the file

Do not mix adopted current rules, proposal-stage ideas, market commentary, supplier estimates, and adviser conclusions into one unlabelled column. The file should preserve source status because future reviewers need to know which rows are current-rule preparation and which rows are only watch items.

Also avoid turning the file into a private law manual. The practical job is to organise data and evidence. Classification decisions, final declarations, authority interactions, and professional conclusions belong in the official or expert-review process, not in hidden spreadsheet wording.

How CBAM Pulse fits the workflow

CBAM Pulse already breaks the import-file job into safer steps: check goods by CN code, estimate threshold exposure, request supplier data, record evidence references, track gaps, watch source-linked updates, and assemble a preparation pack for review.

The product path is deliberately preparation-focused. It helps build the import file and surface missing information. It does not replace official sources, qualified advisers, National Competent Authorities, or the CBAM Registry process.