CBAM exporter–importer data flow: who reports and who provides data
One of the most common points of confusion in CBAM is who actually reports. At a high level, the EU-side importer — as, or through, an authorised CBAM declarant — generally carries the CBAM obligation in the EU, while the non-EU producer or exporter typically provides the embedded-emissions data that supports it (Regulation (EU) 2023/956). This guide sketches that data flow so both sides understand the handoff. It is informational, avoids describing CBAM Registry mechanics, and points you to your national competent authority and adviser for anything specific.
Last updated: 4 July 2026Sources: Regulation (EU) 2023/956European Commission — CBAM
Two roles, one data flow
CBAM connects two parties who often sit in different countries: the EU importer bringing goods into the customs territory, and the non-EU installation or producer that made them. The obligation and the data originate in different places, which is exactly why the handoff causes confusion.
The short version: the EU obligation sits on the EU side; the primary emissions data sits on the production side.
The EU importer / authorised declarant side
In the definitive period, importing CBAM goods into the EU is tied to authorised CBAM declarant status, held by or on behalf of the EU-side importer through the national competent authority (Regulation (EU) 2023/956). That side is where the EU reporting obligation generally lands.
The guide on authorised CBAM declarant status covers what that role involves in more detail.
The non-EU producer / exporter side
A non-EU producer or exporter is generally not the party reporting in the EU system; its practical role is usually to provide the embedded-emissions data and supporting evidence for the goods it makes, so the EU-side declarant can report accurately.
Getting that data across cleanly — for the right goods, with the evidence behind it — is where most of the friction lives, which is why clear requests and organised evidence matter on both sides.
Verify the specifics
This is a high-level orientation, not a rule about any particular company's position. Exactly who holds which role in a given supply chain can depend on the contracts and customs arrangements involved, so verify the specifics with your national competent authority or a qualified adviser rather than assuming from a general map.