Do EU Importers Need to Complete a CBAM Customs Questionnaire?

2026-09-16 17:03:39

Do EU Importers Need to Complete a CBAM Customs Questionnaire?

If you are an EU importer and your customs broker has recently sent you a CBAM questionnaire, you may be wondering:

“Do I have to complete this questionnaire before my goods can clear customs?”

The short answer is:

Not every CBAM questionnaire is asking for the same information, and a Customs Clearance questionnaire should not be confused with the full CBAM emissions reporting process.

However, if your goods fall under CBAM, you should not simply ignore a request from your customs broker. The first step is to understand what information they are asking for and whether your imports are subject to CBAM requirements.

1. What Is a CBAM Customs Questionnaire?

In practice, EU importers may receive different types of CBAM-related questionnaires or information requests.

Type 1: Emissions Data Questionnaire

This type of questionnaire may ask for information such as:

Manufacturer and production facility

Production process

Embedded carbon emissions

Direct and indirect emissions

Other information needed for CBAM reporting

This information is mainly related to your CBAM reporting and annual declaration, rather than simply completing customs clearance.

Under the definitive CBAM regime, importers must report embedded emissions for covered goods. They may use actual emissions data or applicable default values. If actual emissions are used, the relevant emissions data from the non-EU producer must meet the applicable verification requirements.

Type 2: Customs Clearance Information

Your customs broker may also ask you to confirm information such as:

CN code

Whether the goods are covered by CBAM

Import quantity

CBAM authorization or account information

Other information required for the customs declaration

This type of request is more directly connected with customs clearance.

Since 1 January 2026, the CBAM definitive regime has been in force, and CBAM authorization information is integrated with EU customs systems. Customs validates the relevant CBAM authorization before release for free circulation.

So, if your customs broker asks you for CBAM-related information, it is important to understand what they need and why, rather than assuming that every questionnaire is an emissions report.

2. How Can EU Importers Check Whether CBAM Applies?

Before worrying about the questionnaire, check these three points.

Step 1: Check the CN Code

Do not assume that every steel or aluminium product is automatically subject to CBAM.

CBAM currently covers selected goods in six main sectors:

Cement

Iron and steel

Aluminium

Fertilisers

Electricity

Hydrogen

Whether your product is covered depends on the specific CN code and the goods listed under CBAM, not simply on the material name.

For example, saying “this is a steel product” is not enough. You should first confirm the exact customs classification.

Step 2: Check Your Annual Import Volume

For the definitive CBAM regime starting in 2026, the EU uses a single mass-based threshold of 50 tonnes of CBAM goods.

If an EU importer or its indirect customs representative imports more than 50 tonnes of CBAM goods into the EU, the importer must apply for authorised CBAM declarant status.

This means importers should look at their total relevant annual CBAM imports, rather than judging the requirement based only on one shipment.

Step 3: Prepare the Required Information

If your imports are within the CBAM scope, do not wait until the goods arrive at the port to start collecting information.

Depending on your situation, you may need to prepare:

CN code

Product description and specifications

Country of origin

Manufacturer and production facility

Import quantity

Embedded emissions data

CBAM authorization information

Supporting documents for CBAM reporting

The European Commission's CBAM Registry provides functions for authorization, emissions data and reporting. Non-EU installation operators can also share installation and emissions information through the CBAM system.

3. Does CBAM Require Carbon Emissions Data During Customs Clearance?

This is one of the most common questions from EU importers.

The important distinction is between customs clearance and CBAM reporting.

A customs broker may need CBAM-related information to complete or validate the customs declaration. However, that does not mean the importer must submit the full set of embedded emissions data to customs every time goods enter the EU.

The emissions information is primarily needed for the CBAM declaration and related compliance obligations.

For example, the European Commission states that authorised CBAM declarants must report the embedded emissions of imported CBAM goods. The first annual CBAM declaration covering 2026 imports is due in 2027.

Therefore:

“The customs broker asked for CBAM information” does not automatically mean “I must provide the complete carbon emissions report before customs clearance.”

You should first clarify exactly what information the broker is requesting.

4. Two Common CBAM Misunderstandings

Misunderstanding 1: All Steel and Aluminium Products Need CBAM

Not necessarily.

CBAM is based on the specific goods and CN codes covered by the regulation.

Therefore, checking the customs classification is one of the first things an importer should do.

Do not decide whether CBAM applies simply because a product is made from steel or aluminium.

Misunderstanding 2: CBAM Is the Chinese Exporter's Responsibility

The EU importer should not assume that the Chinese supplier is responsible for the entire CBAM process.

The main CBAM compliance responsibility lies with the EU importer or, where applicable, its indirect customs representative.

However, the Chinese manufacturer or supplier may still need to provide important information about the production facility and embedded emissions.

This means CBAM compliance often requires cooperation between the EU importer, customs broker and non-EU supplier.

5. What Should You Do If Your Customs Broker Sends You a CBAM Questionnaire?

Instead of asking only:

“Do I have to fill it in?”

ask these four questions:

1. Is my CN code covered by CBAM?

2. How much CBAM-covered goods am I importing during the year?

3. Is this questionnaire for customs clearance or for CBAM emissions reporting?

4. If emissions data is required, can my Chinese supplier provide the necessary information?

This simple check can help prevent unnecessary delays and avoid last-minute problems.

6. A Practical CBAM Checklist for EU Importers

Before importing CBAM-covered goods from China, check:

☐ Confirm the correct CN code

☐ Check whether the goods are covered by CBAM

☐ Calculate your annual CBAM import volume

☐ Check whether the 50-tonne threshold applies to your imports

☐ Confirm your authorised CBAM declarant status if required

☐ Ask your customs broker what CBAM information is required for customs clearance

☐ Ask your supplier for the necessary emissions information

☐ Keep relevant import and CBAM records

☐ Prepare emissions data well before the annual CBAM declaration deadline

Conclusion: Don't Ignore a CBAM Questionnaire—Find Out What It Is Asking For

For EU importers, receiving a CBAM questionnaire does not automatically mean that a complete carbon emissions report must be submitted before customs clearance.

The more important questions are:

Does my CN code fall under CBAM?

Does my annual import volume exceed the 50-tonne threshold?

Is my customs broker asking for clearance information or emissions data for CBAM reporting?

Do I have the required CBAM authorization and supplier data?

For imports from China, it is especially useful to confirm these points before the goods are shipped. Getting the CN code, CBAM status, import volume and supplier information ready in advance can make both customs clearance and later CBAM compliance much easier.

Note: CBAM rules and operational guidance may be updated by the European Commission. Importers should check the latest official EU guidance and their national competent authority before making compliance decisions.

FAQ:

1. Do EU importers need to complete a CBAM customs questionnaire?

Not necessarily. A CBAM-related questionnaire may be used to collect customs clearance information or carbon emissions data for CBAM reporting. EU importers should first confirm with their customs broker what information is required and why.

2. Do CBAM goods need carbon emissions data for customs clearance?

Not necessarily. Full embedded emissions data is mainly required for CBAM reporting and the annual CBAM declaration. However, customs brokers may request certain CBAM-related information before the goods are released.

3. What is the 50-tonne CBAM threshold for EU importers?

From 2026, the CBAM definitive regime uses a 50-tonne annual mass-based threshold for covered CBAM goods. Importers whose relevant annual imports exceed this threshold need to pay particular attention to CBAM authorisation and reporting requirements.

4. Are all steel and aluminium products imported into the EU subject to CBAM?

No. CBAM does not automatically apply to every steel or aluminium product. Importers should check the specific CN code and confirm whether the product is included in the CBAM scope.

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