Does the CBAM Registry match your imports?

Since 2026, customs authorities pass the data of your import declarations to the CBAM Registry. In the Registry you can see it under "Goods and emissions", added up per day, country of origin and CN code. Your annual CBAM declaration will be held up against that data. So it matters that every import of CBAM goods actually arrived there.

When we compared importers' own customs declarations with the Registry, line by line, the Registry showed fewer tonnes. Not because the goods were not CBAM goods, but because some declarations never reached it, or reached it without a link to the importer's account.

Why declarations go missing

• An anti-dumping or countervailing additional code. Steel fasteners from China often carry a TARIC additional code such as C999 or C856. In the data we have seen, goods items with such a code did not reach the Registry, even when the rest of the same declaration did. The goods are CBAM goods all the same. We have asked the Danish Customs Agency (Toldstyrelsen) why.
• A wrong CBAM account number under Y128. The broker typed the application number ("APPL-…") instead of the account number, a space instead of a hyphen, a number cut short, or "not covered". The Registry cannot link those lines to your account.
• No account number at all. Without a Y128 reference there is nothing to link the line to.
• The de minimis code Y137 in a year above 50 tonnes. Y137 says you stay below the threshold. Most Y137 declarations we saw did reach the Registry, but once it is foreseeable that you pass 50 tonnes, your declarations should carry Y128 with your account number instead.
• Timing. A declaration lodged a few days before you look may simply not have been accepted or passed on yet. Look again a week later.

How to check

1. Copy the Registry's "Goods and emissions" table for the year, with no aggregation, so you get one row per day, origin and CN code.
2. Collect your customs declarations for the same period, and SKAT's monthly import specification, which shows the day customs accepted each declaration.
3. Match them on the day, the country of origin and the CN code. A Registry row can hold several declarations of the same day while showing only one number, so compare tonnes, not only numbers.
4. Give every difference a reason, and decide who acts on it: your broker, the authorities, or nobody yet.

CBAM Wise does this on the Imports page under Reconciliation: upload the Registry table, and every line the Registry does not have gets its reason, with the tonnes per quarter adding up to the difference.

Who to ask what

• Your broker, for wrong or missing account numbers and the use of Y137: they apply for the amendment, with your power of attorney. CBAM Wise lists the declarations per broker and drafts one email with all of them.
• Toldstyrelsen, for customs data that does not reach the Registry, and for amending a declaration yourself. Their page "Sådan ændrer du din toldangivelse" explains how.
• The Danish Energy Agency ([email protected]), for questions about the CBAM rules themselves, for example whether goods missing from the Registry still belong in your declaration.

Whatever the Registry shows, keep counting all your CBAM goods. The obligation follows your imports, not the Registry's table.