On 27 September 2026, according to the German Emissions Trading Authority, the interim situation ends in which an importer may keep importing provisionally without authorisation (DEHSt). Anyone who filed in time works under tolerance until then; afterwards the decision notice determines whether the goods reach the customs territory at all. Nothing changes in the shop. Everything connected with importing changes in the ERP behind it: the cumulative annual quantity per importer, the eight-digit CN code per line, the country of origin, the TARIC document code in the customs declaration. This article shows which fields an ERP integration has to carry, and where the chain tends to break.
Key takeaways
- Since 1 January 2026, CBAM goods above the threshold may be imported only by an authorised CBAM declarant (DEHSt). The threshold is 50 tonnes of net mass per importer and calendar year; it does not apply to electricity and hydrogen (CBAM Regulation 2023/956).
- Anyone who filed an application for authorisation by 31 March 2026 may keep importing provisionally until the authority decides (CBAM Regulation 2023/956). The DEHSt expects that situation to end by 27 September 2026 at the latest (DEHSt) - a tolerance with an expiry date.
- The 50 tonnes are an annual total across four sectors: cement, iron and steel, fertilisers and aluminium (DEHSt). No single movement breaches that limit; the sum does - and only the system of record builds the sum.
- Below the threshold the exemption is not automatic: the TARIC document code Y137 belongs in every customs declaration in ATLAS (DEHSt). Above it, Y128 evidences the CBAM account number plus the EORI numbers of importer and declarant (DEHSt).
- The first CBAM declaration for calendar year 2026 is due by 30 September 2027 (CBAM Regulation 2023/956). Its data basis is created in every customs declaration of the current year; afterwards it can only be reconstructed from documents.
What runs out on 27 September 2026
The definitive period of the carbon border adjustment mechanism started on 1 January 2026. Since then, importing CBAM goods other than electricity and hydrogen above the threshold has been possible only as an authorised CBAM declarant (DEHSt). To keep that cut from stopping every goods flow overnight, the legislator added a transitional rule: anyone who filed an application under Article 5 by 31 March 2026 may keep importing provisionally until the application has been decided (CBAM Regulation 2023/956). The DEHSt puts the end of that situation at 27 September 2026 at the latest (DEHSt). The date is not a statutory deadline but the arithmetic of filing cut-off plus processing time - which is why it appears in no regulation you could file away.
The competent authority assesses an application for authorisation within 120 calendar days of receiving it (Implementing Regulation 2025/486); on that regular period an application filed on 31 March 2026 would be decided at the end of July. Where the authority requests additional information, the period is extended, and the assessment may not take longer than 180 calendar days from receipt in total (Article 5(4) Implementing Regulation 2025/486). Only that outer limit carries an application filed on the last day of the filing window into September on paper. Between the day the tolerance ends and the day the notice arrives lies a span nobody in the company controls. How customs data should travel through a system chain is set out in the article on the 2026 customs reform.
The 50 tonnes are built in the ERP, not at the customs desk
The mass-based threshold is set at 50 tonnes of net mass (CBAM Regulation 2023/956). What matters is the wording behind it: per importer and calendar year, cumulated across the cement, iron and steel, fertiliser and aluminium sectors (DEHSt). That moves the level of assessment. The de minimis rule it replaced applied to goods not exceeding 150 EUR per consignment (Regulation 2025/2083) - a test a single consignment answers on its own. An annual total cannot: it is a running calculation across every customs declaration of a year, and no individual document says whether it breaches the threshold.
| Feature | Until 31 December 2025 | Since 1 January 2026 |
|---|---|---|
| De minimis rule | 150 EUR per consignment (Regulation 2025/2083) | 50 tonnes per importer and calendar year (CBAM Regulation 2023/956) |
| Level of assessment | the single movement | the annual total across four sectors (DEHSt) |
| Condition for importing | reporting duty in the transitional period | authorisation as a CBAM declarant from 01.01.2026 (DEHSt) |
| Evidence in ATLAS | no CBAM document code | Y137 below the threshold, Y128 above it (DEHSt) |
| Penalty range | 10 to 50 euros per tonne of unreported emissions (DEHSt) | 100 euros per certificate not surrendered (DEHSt) |
| Reporting form | quarterly report | one declaration per calendar year by 30 September (CBAM Regulation 2023/956) |
The Commission estimates that the simplification exempts around 90 % of importers from CBAM obligations while at least 99 % of embedded emissions stay in scope (European Commission). For an individual business the share says only that the remaining group is small and that the volumes sit inside it - anyone trading steel sections, rebar, aluminium semi-finished products or cement belongs to it after a handful of consignments. The same pattern applies to the EUDR due diligence data that comes out of the ERP; there too, a filing rarely fails on the text but on a single field.
The 150-euro limit still sits in a lot of documentation
Which fields the customs declaration requires
For each import, the customs authorities transmit a fixed data package to the Commission: the EORI number or the corresponding form of identification, the CBAM account number of the authorised declarant, the eight-digit CN code of the goods, the quantity, the country of origin, the date of the customs declaration and the customs procedure (CBAM Regulation 2023/956). That list is the requirements catalogue for the ERP. It still meets master data maintained for a different purpose: the commodity code six digits instead of eight, the country of origin equal to the country of dispatch, the quantity in pieces instead of kilograms of net mass. How to bring such fields into line without duplicate maintenance is covered in the article on data mapping between ERP and shop.
Eight-digit CN code
What is transmitted is the eight-digit CN code of the goods (CBAM Regulation 2023/956). Eight digits, not six: many item masters carry only the Harmonised System heading, which was enough for export statistics.
Quantity as net mass
The threshold is set at 50 tonnes of net mass (CBAM Regulation 2023/956). Net mass means without packaging - the weight field maintained least often in the shipping module.
Country of origin
What is required is the country of origin, not the country of dispatch (CBAM Regulation 2023/956). In real data the two diverge as soon as a transit warehouse sits in the chain.
EORI and CBAM account
For code Y128 the CBAM account number goes into the document number field, the importer's EORI to the consignee and the declarant's EORI to the declarant (DEHSt).
Date and customs procedure
The date of the customs declaration and the customs procedure travel to the Commission as well (CBAM Regulation 2023/956). Both decide which calendar year a quantity counts towards.
TARIC document code
Y137 declares the exemption below the threshold (DEHSt). The code is one entry per declaration and belongs on the item as an attribute, not in the clearing desk's memory.
The gap between six and eight digits is where most projects take longer than planned. A six-digit heading cannot be extended mechanically; depending on the goods it splits into several subheadings with different CBAM exposure. The assignment is desk work, once per item, and belongs on the master record afterwards. How such a master record should be structured so that several systems read it the same way is covered in the article on master data synchronisation. That several number worlds can coexist without one displacing the other is shown in the article on customer part numbers in the B2B shop.
item:
cn_code_8 "7214 20 00" # eight digits, maintained attribute
cbam_sector iron_steel | cement | fertiliser | aluminium
cbam_in_scope true # result of the assignment, not a formula
line:
net_mass_kg 18450.000 # decimal type, without packaging
country_of_origin "TR" # origin, not dispatch
declaration_date 2026-09-09
customs_procedure "4000"
taric_document "Y128" # Y137 below the threshold
cbam_account "..." # only with Y128
eori_importer "DE..."
eori_declarant "DE..."
annual_total_2026:
sum_net_mass_t 46.9 # rolling, per importer
threshold_t 50.0
warning_level_t 45.0 # 90 percent of the threshold
The chain of deadlines from application to declaration
The dates of 2026 hang together, and on calendar days rather than working days. Laying the chain out once shows why September becomes the bottleneck.
- File the application: an importer or indirect customs representative who filed an application under Article 5 by 31 March 2026 may keep importing provisionally until the authority decides (CBAM Regulation 2023/956).
- Start the consultation: within 45 calendar days of receiving the application, the competent authority starts the consultation procedure through the CBAM registry (Implementing Regulation 2025/486).
- Hear the member states: the consultation itself may not exceed 15 calendar days (CBAM Regulation 2023/956). It runs inside the assessment period, not on top of it.
- Wait out the assessment period: the authority assesses the application within 120 calendar days of receipt (Implementing Regulation 2025/486). For applications filed before 15 June 2025 a period of 180 calendar days applies; the DEHSt quotes the same two values (DEHSt).
- Tolerance ends: provisional importing without declarant status is possible until the application has been decided, that is by 27 September 2026 at the latest (DEHSt).
- Submit the declaration: by 30 September of each year, first in 2027 for the year 2026, the CBAM declaration for the preceding calendar year follows (CBAM Regulation 2023/956).
Two further dates belong in the same calendar because they drive the cash flow. From 1 February 2027 the member states sell CBAM certificates to authorised declarants through a central common platform (CBAM Regulation 2023/956). And on 1 November of each year the Commission cancels all certificates that were bought in the year before the preceding calendar year and remained in the account (CBAM Regulation 2023/956). Buying too much means the repurchase request has to be submitted by 31 October of the year in which the certificates were surrendered (CBAM Regulation 2023/956). Three dates, three directions - all from the same quantity base in the ERP.
One field, one system of record, one total
What a breach costs
In line with the emissions trading directive, the penalty is 100 euros per tonne of carbon dioxide equivalent emitted for which no certificate was surrendered (DEHSt). Paying it does not release anyone from the duty to surrender the missing certificates. Importing above the threshold without authorisation costs three to five times that penalty per missing certificate for the year of the movement (CBAM Regulation 2023/956). Even in the transitional period, penalties of 10 to 50 euros per tonne of unreported emissions applied to missing, incomplete or incorrect reports (DEHSt).
Two forms of mitigation exist, and both are narrow. The competent authority may reduce the increased penalty where an importer exceeded the mass-based threshold by no more than 10 % (CBAM Regulation 2023/956) - at 50 tonnes that is five tonnes of headroom, a single larger consignment. And the Commission provides the authorities with a list of importers exceeding 90 % of the mass-based threshold (CBAM Regulation 2023/956). From 45 tonnes a year a company sits on that list before anyone inside the business had the threshold in view.
- Penalty per missing certificate: 100 euros per tonne of carbon dioxide equivalent emitted, with no release from the duty to surrender (DEHSt).
- Importing without authorisation: three to five times that penalty per missing certificate for the year of the movement (CBAM Regulation 2023/956).
- Mitigation: available where the threshold was exceeded by no more than 10 % (CBAM Regulation 2023/956).
- Early warning to the authorities: a list of importers exceeding 90 % of the threshold (CBAM Regulation 2023/956).
- Reporting failures in the transitional period: 10 to 50 euros per tonne of unreported emissions (DEHSt).
Cumulation is a job for the ERP
The threshold applies per importer, not per order, not per supplier and not per company code. Anyone running several company codes under one EORI number adds up across those company codes; an indirect customs representative adds up across the importers represented, because obligations arise for the representative too once those importers exceed the 50-tonne quantity threshold (DEHSt). This is a modelling question, not a reporting question. How it looks when several legal entities hang off one system is shown in the article on multiple ERP entities on one shop.
Determine exposure per item
Maintain the eight-digit CN code and decide once whether the item falls into one of the four sectors (DEHSt). The result is stored on the master record instead of being derived per movement.
Carry net mass reliably
Kilograms of net mass per line as a separate field, apart from gross and shipping weight. Without that separation the annual total runs too high and the threshold falls too early.
Calculate the annual total on a rolling basis
A running total per importer and calendar year across all customs declarations. Set the warning level at 45 tonnes, because the authority list applies from 90 % of the threshold (CBAM Regulation 2023/956).
Pull the coding from the master record
Y137 below the threshold, Y128 with the CBAM account number and both EORI numbers above it (DEHSt). A rule in the system makes that choice, not the clearing desk.
Keep the evidence linked
Declaration, line, quantity, origin and coding stay retrievable in one linked structure. The 2026 declaration is built in 2027 from those records, not from recollection.
Maintain the eight-digit CN code and decide once whether the item falls into one of the four sectors (DEHSt). The result is stored on the master record instead of being derived per movement.
Kilograms of net mass per line as a separate field, apart from gross and shipping weight. Without that separation the annual total runs too high and the threshold falls too early.
A running total per importer and calendar year across all customs declarations. Set the warning level at 45 tonnes, because the authority list applies from 90 % of the threshold (CBAM Regulation 2023/956).
Y137 below the threshold, Y128 with the CBAM account number and both EORI numbers above it (DEHSt). A rule in the system makes that choice, not the clearing desk.
Declaration, line, quantity, origin and coding stay retrievable in one linked structure. The 2026 declaration is built in 2027 from those records, not from recollection.
Reconstruction is what gets expensive: adding up an annual quantity in the summer of 2027 from invoices, freight papers and mail attachments costs a multiple of the time a maintained flag would have taken. How vouchers and line items are handed between shop and accounting is described in the article on connecting Lexware Office. That the system side is no side issue for the administration either shows in the IT budget: 101.74 million EUR are earmarked for CBAM for 2023 to 2027 (European Commission), and the simplification adds a further 18.95 million EUR in IT costs for 2025 to 2027 (European Commission).
From 2027: the rolling coverage
The year 2027 adds a second calculation. From 2027 the authorised CBAM declarant ensures that the certificates in the account at the end of each quarter cover at least 50 % of the embedded emissions of all goods imported since the start of the calendar year (CBAM Regulation 2023/956). Originally 80 % were foreseen; the simplification reduced the percentage from 80 % to 50 % and factored in the free allocation of allowances under emissions trading (Regulation 2025/2083).
That calculation needs two figures from different corners. The quantity comes from the customs declaration, the emission factor from the supplier or from the default values. The latter are no fixed point: the Commission corrected the implementing regulation on default values, and the correction applies retroactively from 01.01.2026 (DEHSt). A price anchor exists: for the second quarter of 2026 the Commission published a CBAM certificate price of 75.28 euros (DG TAXUD). Anyone carrying quantities in several units will find the conversion rules in the article on units of measure and pack sizes.
The threshold itself is not carved in stone
What to do in the system now
The work of the coming weeks is unspectacular and easy to scope. It is not new software but five fields, one total and one rule that picks the right TARIC document code. For that path a middleware is the usual place, because it keeps the mapping in one spot instead of copying it into every interface. How such a path becomes auditable is described in the article on process documentation under GoBD. The pattern is familiar to anyone tracking batches and serial numbers: there the batch, here the annual quantity - and in both cases the ERP integration carries the evidence.
- Eight-digit CN code maintained per item and stored as an attribute, not derived from a six-digit heading (CBAM Regulation 2023/956).
- Net mass per line as a field of its own, separate from gross and shipping weight (CBAM Regulation 2023/956).
- Rolling annual total per importer across all four sectors, with a warning level at 90 % of the threshold (CBAM Regulation 2023/956).
- Rule for the TARIC document code in place: Y137 below, Y128 with account number and EORI numbers above the threshold (DEHSt).
- Authorisation status and decision date visible in the system so the tolerance does not lapse unnoticed on 27 September 2026 (DEHSt).
- Records linked so that the 2026 declaration can be generated from them by 30 September 2027 (CBAM Regulation 2023/956).
An import without a maintained quantity base is not an offence, it is an open item. It becomes visible only at the moment the annual total has to be built - and by then it lies entirely in the past.
Sources and studies
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