Aigen CBAM is live: EU requirements and app features

Imports made in 2026 fall within the first annual CBAM declaration, due on 30 September 2027. Importers need to collect import and emissions data for the whole year. This article covers the EU requirements, the role of Finnish Customs and how the newly launched Aigen CBAM helps prepare that data.

CBAM is based on EU regulation

The Carbon Border Adjustment Mechanism (CBAM) was established by Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083. It puts a carbon price on the production emissions of certain goods imported into the EU, reflecting carbon costs under the EU Emissions Trading System. The aim is to prevent carbon leakage: production and emissions moving outside the EU.

Its scope covers goods listed in Annex I across six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Whether a product falls within CBAM depends on its CN code, the customs classification; the sector name alone does not settle the question.

Finnish Customs administers CBAM in Finland

The obligations come from EU law. In Finland, the national competent authority is Finnish Customs (Tulli), which handles authorised CBAM declarant applications, guides importers and supervises compliance. Applications are made through the EU CBAM Registry, where annual declarations are also submitted. Finnish administrative guidance is available on Tulli’s CBAM page (in Finnish).

Importers whose combined CBAM imports in the cement, iron and steel, aluminium and fertiliser sectors do not exceed 50 tonnes of net mass per calendar year are exempt from the main CBAM obligations for those goods. This threshold does not apply to electricity or hydrogen. If imports exceed 50 tonnes, the obligations cover the whole year, including consignments imported before the threshold was crossed. Cumulative mass therefore needs to be tracked from the start of the year.

Where imports require authorised CBAM declarant status, apply in advance. During 2026, imports may also continue while an application submitted by 31 March 2026 is still pending. Tulli also explains how to declare imports below the threshold on the customs declaration.

From the transitional phase to the definitive phase in 2026

During the transitional phase, from 1 October 2023 to 31 December 2025, embedded emissions were reported quarterly and no CBAM certificates were purchased. The definitive phase began on 1 January 2026. Emissions are now declared annually, and the corresponding number of certificates, calculated under the rules, must be surrendered.

The first annual declaration covers imports made in 2026. Both the declaration and certificate surrender are due by 30 September 2027; thereafter, the deadline is 30 September of the year following importation. Sales of CBAM certificates on the EU’s common central platform begin on 1 February 2027.

The annual declaration needs quantities of goods, embedded emissions, any carbon price paid in the country of origin and certificate surrender details. Emissions are determined using actual data that meets the rules or Commission default values. Actual emissions data is subject to monitoring and verification requirements. Certificate needs account for the adjustment reflecting free allocation under the EU ETS and any deductible carbon price effectively paid in the country of origin. Free allocation is phased out between 2026 and 2034.

Why we built Aigen CBAM

Preparing the annual declaration requires import, product, supplier and emissions data that often sits in different systems and files. Finding the information is only part of the work: it needs to be linked to the right consignment, and gaps need to become visible early.

We built Aigen CBAM to bring this work into one place. Import and procurement teams can track supplier information and open tasks, finance and compliance teams can prepare the declaration, and management can see preparation status. A shared set of records reduces the need to start searching for the same information again each reporting cycle.

Aigen CBAM features

• Missing-data checklist. See which information is still missing from your imports and what needs completing before declaration preparation.
• AI assistant. Get help with using the app, CBAM questions, filling in forms, handling imports and cleaning up data.
• Finnish and English support. Both the interface and CN code search work in Finnish and English.
• Import register. Record CN codes, net masses, countries of origin, import dates and customs references for each consignment.
• CSV and Excel import. Import existing data from a file and map its columns to the right fields.
• Emissions and certificate calculations. Use actual emissions data or default values. Calculations account for the free allocation adjustment and the gradual phase-out of free allocation.
• Annual threshold tracking. Track cumulative imports against the 50-tonne threshold for the goods it applies to.
• Certificates held versus forecast. Compare the CBAM certificates you hold with the forecast need.
• Supplier invitations without an account. Send a supplier an invitation link to provide emissions data. Review and approve the data yourself, then attach it to the right consignment.
• Annual declaration preparation and export. Prepare declaration data and export it as XML or ZIP for submission to the EU CBAM Registry.
• Audit history. See who changed what and revisit how records were handled.
• Documents. Attach supporting documents to consignments.
• Multiple companies. Manage several companies through one user account, for example an accounting firm’s clients.

Submitting the declaration and buying certificates

Aigen CBAM prepares the data. You submit the declaration to the EU CBAM Registry yourself. Certificates cannot be purchased in the app. Using the AI assistant or exporting data does not replace the required checks and verification.

The service is now available at cbam.fi. Start by gathering your import records and checking which emissions data you still need from suppliers.