CBAM Compliance Timeline
Every key date from the 2023 regulation through the 2027 certificate surrender deadline — with what it means for South African exporters at each stage.
CBAM Regulation Enacted
EU Regulation 2023/956 enters into force. CBAM is officially law across all 27 EU member states.
The Carbon Border Adjustment Mechanism was formally adopted by the European Parliament and Council on 10 May 2023. It applies to imports of iron & steel, aluminium, cement, fertilisers, hydrogen, and electricity.
CBAM Regulation Enacted
EU Regulation 2023/956 enters into force. CBAM is officially law across all 27 EU member states.
The Carbon Border Adjustment Mechanism was formally adopted by the European Parliament and Council on 10 May 2023. It applies to imports of iron & steel, aluminium, cement, fertilisers, hydrogen, and electricity.
Transitional Phase Begins
CBAM enters its transitional period. EU importers must begin collecting embedded emissions data from non-EU suppliers.
During the transitional phase, no financial payments are required. However, EU importers are legally obligated to report the embedded carbon in CBAM goods. SA exporters who cannot provide actual emissions data will be reported under EU default values — which are significantly higher than SA actual values.
Transitional Phase Begins
CBAM enters its transitional period. EU importers must begin collecting embedded emissions data from non-EU suppliers.
During the transitional phase, no financial payments are required. However, EU importers are legally obligated to report the embedded carbon in CBAM goods. SA exporters who cannot provide actual emissions data will be reported under EU default values — which are significantly higher than SA actual values.
First Quarterly CBAM Report Due
EU importers file their first CBAM transitional report covering Q4 2023 (October–December 2023).
The first CBAM Quarterly Report covered embedded emissions from goods imported between 1 October and 31 December 2023. SA exporters who had not yet provided actual emissions data were reported under conservative EU default values.
First Quarterly CBAM Report Due
EU importers file their first CBAM transitional report covering Q4 2023 (October–December 2023).
The first CBAM Quarterly Report covered embedded emissions from goods imported between 1 October and 31 December 2023. SA exporters who had not yet provided actual emissions data were reported under conservative EU default values.
Q2 2024 CBAM Report Due
EU importers file CBAM transitional report for Q1 2024 (January–March 2024).
Q2 2024 CBAM Report Due
EU importers file CBAM transitional report for Q1 2024 (January–March 2024).
Q3 2024 CBAM Report Due
EU importers file CBAM transitional report for Q2 2024 (April–June 2024).
Q3 2024 CBAM Report Due
EU importers file CBAM transitional report for Q2 2024 (April–June 2024).
Q4 2024 CBAM Report Due
EU importers file CBAM transitional report for Q3 2024 (July–September 2024).
Q4 2024 CBAM Report Due
EU importers file CBAM transitional report for Q3 2024 (July–September 2024).
Annual Transitional Report Due
EU importers file consolidated annual CBAM transitional report for all of 2024.
The annual report consolidated all quarterly data from 2024. This was the last major transitional reporting obligation before the full enforcement phase began.
Annual Transitional Report Due
EU importers file consolidated annual CBAM transitional report for all of 2024.
The annual report consolidated all quarterly data from 2024. This was the last major transitional reporting obligation before the full enforcement phase began.
Full CBAM Enforcement Begins
CBAM transitions from reporting-only to full financial enforcement. EU importers must purchase CBAM certificates for all covered goods.
From 1 January 2026, EU importers of CBAM-covered goods must hold a valid CBAM Authorised Declarant status and purchase CBAM certificates equal to the embedded carbon in their imports. SA exporters without actual emissions data face the full EU default emission values — which are 20–40% higher than SA actual values.
Full CBAM Enforcement Begins
CBAM transitions from reporting-only to full financial enforcement. EU importers must purchase CBAM certificates for all covered goods.
From 1 January 2026, EU importers of CBAM-covered goods must hold a valid CBAM Authorised Declarant status and purchase CBAM certificates equal to the embedded carbon in their imports. SA exporters without actual emissions data face the full EU default emission values — which are 20–40% higher than SA actual values.
EU CBAM Registry Opens
The EU CBAM Registry goes live. Authorised Declarants can register, submit declarations, and purchase CBAM certificates.
The EU CBAM Registry is the central platform for all CBAM financial transactions. Only Authorised Declarants registered in the Registry can import CBAM-covered goods into the EU. SA exporters must ensure their EU buyers are registered and have the correct embedded emissions data.
EU CBAM Registry Opens
The EU CBAM Registry goes live. Authorised Declarants can register, submit declarations, and purchase CBAM certificates.
The EU CBAM Registry is the central platform for all CBAM financial transactions. Only Authorised Declarants registered in the Registry can import CBAM-covered goods into the EU. SA exporters must ensure their EU buyers are registered and have the correct embedded emissions data.
SA Carbon Tax Rate Increases to R236/tCO₂
South Africa's carbon tax rate increases to R236 per tonne of CO₂ equivalent under the Carbon Tax Act Amendment.
The SA carbon tax rate increase to R236/tCO₂ is directly relevant to CBAM calculations. SA exporters can deduct their SA carbon tax payments from their CBAM certificate obligations — but only if they can document the payments. The higher the SA carbon tax rate, the larger the potential CBAM deduction.
SA Carbon Tax Rate Increases to R236/tCO₂
South Africa's carbon tax rate increases to R236 per tonne of CO₂ equivalent under the Carbon Tax Act Amendment.
The SA carbon tax rate increase to R236/tCO₂ is directly relevant to CBAM calculations. SA exporters can deduct their SA carbon tax payments from their CBAM certificate obligations — but only if they can document the payments. The higher the SA carbon tax rate, the larger the potential CBAM deduction.
First Annual CBAM Declaration Due
EU Authorised Declarants must file their first annual CBAM declaration covering all CBAM goods imported in calendar year 2026.
The annual CBAM declaration must include: the total quantity of each CBAM good imported, the actual embedded emissions (or EU default values if actual data is unavailable), the carbon price paid in the country of origin, and the number of CBAM certificates to be surrendered.
First Annual CBAM Declaration Due
EU Authorised Declarants must file their first annual CBAM declaration covering all CBAM goods imported in calendar year 2026.
The annual CBAM declaration must include: the total quantity of each CBAM good imported, the actual embedded emissions (or EU default values if actual data is unavailable), the carbon price paid in the country of origin, and the number of CBAM certificates to be surrendered.
First CBAM Certificate Surrender Deadline
EU Authorised Declarants must surrender CBAM certificates equal to the embedded carbon in all CBAM goods imported in 2026.
This is the first hard financial deadline. Failure to surrender sufficient CBAM certificates results in a penalty of EUR 100 per tonne of CO₂ equivalent (Article 26 of EU Regulation 2023/956), plus potential criminal liability for deliberate evasion. SA exporters whose EU buyers cannot surrender certificates will lose those contracts.
First CBAM Certificate Surrender Deadline
EU Authorised Declarants must surrender CBAM certificates equal to the embedded carbon in all CBAM goods imported in 2026.
This is the first hard financial deadline. Failure to surrender sufficient CBAM certificates results in a penalty of EUR 100 per tonne of CO₂ equivalent (Article 26 of EU Regulation 2023/956), plus potential criminal liability for deliberate evasion. SA exporters whose EU buyers cannot surrender certificates will lose those contracts.
Annual CBAM Cycle Continues
CBAM becomes a permanent annual compliance cycle: declare by 31 May, surrender certificates by 30 September each year.
From 2028, CBAM is a permanent feature of EU trade. The scope may expand to include additional sectors (polymers, organic chemicals, and other carbon-intensive goods) under the EU's broader carbon border policy review scheduled for 2026.
Annual CBAM Cycle Continues
CBAM becomes a permanent annual compliance cycle: declare by 31 May, surrender certificates by 30 September each year.
From 2028, CBAM is a permanent feature of EU trade. The scope may expand to include additional sectors (polymers, organic chemicals, and other carbon-intensive goods) under the EU's broader carbon border policy review scheduled for 2026.
What This Timeline Means for SA Exporters
Full enforcement started 1 January 2026. Every shipment of steel, aluminium, cement, fertilisers, or hydrogen to the EU now triggers a CBAM certificate obligation for your EU buyer. If they cannot document your actual emissions, they pay for EU default values — and pass the cost back to you.
30 September 2027 is the first certificate surrender deadline. Your EU buyers must surrender CBAM certificates for all 2026 imports by this date. If they fail, they face EUR 100/tCO₂ penalties — and will immediately stop buying from non-compliant SA suppliers.
SA exporters who can document their SA carbon tax payments (R236/tCO₂ from April 2026) can deduct this from their CBAM certificate obligation. This is a significant cost advantage — but only if you have the documentation and your EU buyer knows how to claim the deduction.
Don't Miss the 30 September 2027 Deadline
Start your CBAM compliance registration now. Gate 2 of the Three Keys ecosystem handles your CBAM Financial Authorisation — so your EU buyers can surrender certificates and keep buying from you.