Custom CBAM declaration software development
Since 1 January 2026, CBAM has entered its definitive phase: if you import more than fifty tonnes of CBAM goods a year, you must do so as an authorised declarant, file an annual declaration on the embedded emissions and surrender certificates for them. Appfront builds the software that collects those emissions data per consignment from your suppliers and links it to your customs declarations.
What CBAM requires of you in the definitive phase
The carbon border adjustment mechanism accounts for the CO2 emissions from producing certain imported goods, so that production outside the EU does not become cheaper because of lower climate costs. It covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, as well as a range of processed products made from them. The definitive phase began on 1 January 2026; before that, a lighter reporting period applied.
There is a threshold: importers who bring less than fifty tonnes of CBAM goods into the EU in a calendar year fall outside the obligations. That exemption does not apply to hydrogen and electricity. If you exceed the threshold, you may only import those goods as an authorised CBAM declarant, you file an annual declaration of the embedded emissions, and you surrender certificates for them. From 2027 onwards, you must also hold sufficient certificates in your CBAM account every quarter.
The difficult part isn't the declaration but the figure beneath it. The embedded emissions of a consignment must come from the producer outside the EU, per installation and per type of good, and must match the commodity codes in your customs declaration. Your supplier often doesn't have that data to hand and doesn't speak your language on this subject. Collecting, checking and linking it is the real work, and it happens all year round, not just in declaration week.
CBAM rarely stands alone. If you import goods that you process yourself, it touches your production planning and the question of which purchases ended up in which end product. The supplier data you gather for this is often also used for your sustainability reporting. We build those connections as integrations, not as exports.
How we build your CBAM software
We start with the flow of goods and the suppliers, not with the declaration form. Once the emissions data arrives per consignment, the declaration becomes a matter of addition.
Which goods codes you import, from which countries, from which producers and above which volume. This determines whether you exceed the threshold and which flows genuinely need attention. Often a small share of suppliers accounts for most of the emissions.
We design how you request emissions data: which form, which fields, which language and which supporting evidence. This process is the weakest link, so it must be as simple as possible for the producer and as verifiable as possible for you.
We work in sprints and start by linking consignments to customs declarations, because that is the foundation. Your purchasing team and your customs officer work with us, and we test every sprint against real consignments from the current year.
We have the software calculate a closed period and set the outcome against what you had determined yourselves. Discrepancies almost always point to missing supplier data or a goods code that was not classified correctly.
What the software actually does
Six components that together make the declaration possible. Which you need depends on how many suppliers and goods codes are involved.
Consignments from your customs declarations
Import declarations form the basis: goods code, quantity, country of origin and producer per consignment. We retrieve this from your customs software or freight forwarder so that the CBAM administration rests on the same figures as your declaration, rather than on a parallel count.
Supplier portal
Your producer submits its emissions data via a form that asks for what CBAM requires: per installation, per type of good, with the method used. That is better than an email exchange in spreadsheets, where every supplier chooses its own layout.
Embedded emissions per consignment
The values supplied are allocated to the consignments they belong to, with direct and, where applicable, indirect emissions shown separately. Where data is missing, it is visible which consignment is still open, rather than quietly being filled in.
Checking what comes in
Values that deviate sharply from previous deliveries by the same producer, or from what is typical for that type of good, are flagged. That is not a judgement but a signal to ask questions before the figure ends up in your declaration.
Tracking the certificate position
From 2027, you will need to have sufficient funds in your CBAM account every quarter. The software factors in your ongoing obligation as the year progresses, so buying certificates becomes a matter of planning rather than a surprise.
Dossier per reporting year
For each year, what has been declared, based on which supplier data and which method, with the supporting documents attached. When the regulator carries out an inspection, you show the underpinning rather than having to reconstruct it.
Who we build for
Four types of importer. The difference lies mainly in the number of suppliers and in how many processed products run through your flow.
Producers importing semi-finished goods
Steel, aluminium or components you process yourself. Here CBAM and your production records overlap, as you need to know which purchases ended up in which finished product.
Trade and distribution
Many consignments, many commodity codes and a supplier file that keeps changing. Here the portal is the centre of gravity: without a scalable way to retrieve data, it becomes manual work.
Construction and civil engineering
Cement, steel and building products with a large mass, so the threshold is quickly exceeded. Often via a trading party, and then the question is who is formally the declarant.
Businesses around the threshold
You are around fifty tonnes and are not sure which side you fall on. Then the first gain is visibility of your own volume per commodity code, before you commission a system you may not need.
Test your idea first: a working prototype in 1 day
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What we use depends on your situation. Declarations are submitted in the authorities' CBAM registry; our software prepares and substantiates the data, and does not submit independently unless an interface for that proves to be available.
If you are unsure whether you exceed the annual threshold, there is our tonnage monitor for CBAM goods.
Why Appfront
The supplier is the bottleneck
Your declaration is only as good as what your producer supplies. That is why we invest most in that process: a form they understand, in their language, with only what is needed.
One figure, two declarations
CBAM and your customs declaration must align. By building the CBAM records on the same consignments, they cannot drift apart.
All year round, not just in declaration week
Requesting emissions data takes weeks because a person is on the other end. We set it up as a continuous process that asks per consignment, so the declaration becomes a summation.
Honest about what is still moving
The implementing rules for CBAM have been amended several times recently. We therefore build the calculation rules and methods as configurable components, so that a change does not become a rebuild.
Security and privacy
CBAM data contains little personal data but sensitive business information: which producers you use, which volumes you purchase and against which production methods. The same applies to your supplier: their emissions figures per installation say something about their process. We therefore keep access tight and ensure that a supplier in the portal sees only their own data and never that of another.
Because the declaration may be checked by the supervisory authority, the reliability of the supporting evidence matters. All submitted values are stored as they were received, together with who submitted them and when; any later correction is visible as a correction and does not overwrite the original. The calculation method used is also recorded per declaration year, since it can change while your earlier declarations remain based on the rules that applied at the time. How we handle security ourselves is set out in our information security policy; reports from outside go through our CVD policy.
Frequently asked questions about CBAM
There is a threshold of fifty tonnes of CBAM goods per calendar year. If you remain below it, the obligations fall away. An important exception: that exemption does not apply to hydrogen and electricity. If you are near the threshold, keep track of your volume per commodity code, as the limit applies to the total of CBAM goods rather than per type. That insight is often the first task and sometimes the last.
Among others, iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, plus a range of processed products made from these. Those processed products are often overlooked: an imported steel component may fall under CBAM even though you buy it as a component rather than as steel. The commodity code is decisive, and classifying it correctly is one of the first things we map out.
The greenhouse gases released during the production of the good, attributed per tonne of product. For some types of goods only direct emissions count, for others indirect emissions count too, such as the emissions from electricity used. These values must come from the producer, per installation. We build the process to obtain and verify them; determining them remains the work of your supplier and its verifier.
That is the most common problem, and it is not a software problem. There are fallback options that use default values, but these usually work out less favourably than actual data. In practice, the best approach is to put the requirement into your purchasing terms and to make supplying the data as straightforward as possible. Our software shows which suppliers are lagging behind and what that is likely to cost you.
The declaration for a calendar year is accompanied by surrendering certificates for the corresponding emissions. In addition, from 2027 you must hold a sufficient position in your CBAM account at the end of each quarter during the year. That makes it a question of liquidity as well as administration: our software therefore factors the ongoing obligation into the calculation as the year progresses.
The declaration runs through the authorities' CBAM registry. We prepare the data in the required format and keep the supporting evidence, but we do not promise automatic submission until we have established which interface is available for that. The implementing rules around CBAM have been amended several times recently, and we would rather say now what we don't know than halfway through.
Supervision is shared: the European Commission, the Netherlands Enterprise Agency (RVO) and Customs each have a role. The NEa assesses signals and oversees compliance in the Netherlands. In practice, your CBAM records must align with what Customs has seen at import; if they diverge, that is the first thing to stand out.
Partly in the data, not in the system. A sustainability report covers your own supply chain and your own annual report; CBAM covers specific goods at import, per consignment and per commodity code. What you can do is collect the supplier data once and use it for both. We set up the storage with that in mind.
Ready to build your CBAM software?
Tell us which goods you import and from which producers, and we will tell you whether you exceed the threshold, where your emissions data needs to come from and which part will take the most work. We build this as a standalone application and as part of a wider custom software project. If you also import commodities carrying deforestation risk, the EUDR applies as well; see EUDR software.
If the broader customs and VAT side also applies to you, look at software for fiscal representation and customs administration and at the app for on-site goods flow.