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ETS€75.36/tPHASE-IN 20262.5%SURRENDER30 SEP 2027CERT PURCHASE OPENS1 FEB 2027Reg (EU) 2023/956ACTIVEIR (EU) 2025/2621ACTIVEIR (EU) 2025/2620ACTIVEReg (EU) 2025/2083ACTIVEXSDMONITOREDSECTORS IN SCOPE6
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Guide 02

How CBAM declarations work

The XML file, what it contains, who files it, and the EU Registry.


Section 01

The XML file

A CBAM declaration is not a form or a spreadsheet. It is a structured XML file that conforms to the schema published by the Commission for the CBAM Registry. The schema fixes the elements, data types, and code lists the file must use, and the Registry validates every submission against it before accepting it.

Because the format is rigid, a single mismatched code, missing element, or malformed value causes the Registry to reject the file. The XML is the deliverable that matters; everything upstream exists to produce it correctly.

Section 02

What it contains

For each consignment, the declaration carries the CN code of the good, the country of origin, the quantity, and the embedded emissions — direct and, where required, indirect — expressed per tonne of product and in total. It also records the production route, the determination method (actual or default), and any carbon price already paid at origin that is eligible for deduction.

CN code
Good classification
Origin
Country of production
tCO₂e
Embedded emissions

Implementing Regulation (EU) 2025/2547

Lays down the methods for calculating the emissions embedded in goods declared for the definitive period.

Section 03

Who files it

The EU importer is the declarant of record. It holds the authorisation, submits the declaration, and surrenders the certificates. A non-EU producer cannot file with the Registry; its role is to supply verified emissions data to its EU customer.

Regulation (EU) 2023/956 — Art 6 & Art 10

The authorised CBAM declarant submits the annual CBAM declaration; installation operators in third countries may register their data so it can be used by declarants, but they do not file the declaration.

Carbon Mandate sits between the two. We prepare and check the data and the XML in the producer’s own language and local context, then hand a Registry-ready package to the EU importer to file. Preparer, not filer; never the verifier.

Section 04

The EU Registry

The CBAM Registryis the Commission’s central system for the definitive period. Declarants authenticate, upload the XML declaration, and manage their certificate account through it. The Registry runs schema and business-rule validation on submission and returns errors that must be cleared before the declaration is accepted.

Getting a clean acceptance on the first attempt depends entirely on the file being correct before it reaches the Registry — which is the work that happens before filing, not during it.

Next guide03 CN codes & sectors