If your company imports cement, steel, aluminum, fertilizers, hydrogen, or electricity into the EU, you are now subject to the Carbon Border Adjustment Mechanism (CBAM). Since 1 October 2023, importers must submit quarterly reports detailing the embedded emissions of imported goods.
While the transitional phase (2023-2025) does not yet require purchasing CBAM certificates, accurate reporting is mandatory. Non-compliance results in penalties of €10 to €50 per tonne of unreported goods—and from 2026, financial obligations begin with certificate purchases tied directly to the emissions data you report today.
This guide provides a step-by-step framework for EU importers to:
Understanding Your Role as a CBAM Reporting Declarant
Who is the Reporting Declarant?
Under CBAM, the "reporting declarant" is the entity responsible for submitting quarterly reports to the European Commission. This can be:
Key point: Every tonne of imported goods must be reported by exactly one declarant—no double reporting, no omissions.
What Must Be Reported?
For each quarter, you must report:
|
Category |
Details Required |
|
Goods Imported |
CN code, quantity (tonnes or MWh), country of origin, installation details |
|
Embedded Emissions |
Direct emissions, indirect emissions (separately), total CO₂e per tonne |
|
Production Details |
Production route, relevant parameters (e.g., clinker content for cement) |
|
Carbon Price Due |
Any carbon pricing paid in the country of origin, rebates received |
Step-by-Step: How to Complete CBAM Quarterly Reports
Step 1: Identify CBAM Goods in Your Imports
Not all products fall under CBAM. Use the Combined Nomenclature (CN) codes listed in Annex I of the CBAM Regulation to determine if your imports are in scope.
CBAM-covered sectors:
Tool: Use the TARIC consultation tool (RAMON database) or run the CBAM Checker [MW1] to confirm if your goods are covered.
Step 2: Request Emissions Data from Suppliers
Your non-EU suppliers (manufacturers/operators) must provide you with specific embedded emissions for each shipment or reporting period.
What to request from suppliers:
✅
Direct emissions (tonnes CO₂e per tonne of product)
✅ Indirect
emissions (from electricity consumption)
✅ Production
route (e.g., blast furnace vs. electric arc furnace for steel)
✅ Sector-specific
parameters (e.g., alloy content, scrap usage %)
✅ Carbon price
paid in the country of origin (if applicable)
✅ Reporting
period used by the supplier (calendar year, fiscal year, etc.)
Recommended approach: Share the European Commission's voluntary communication template (Excel-based) with your suppliers. This standardizes data exchange and reduces errors.
Challenge: Many suppliers outside the EU may not yet have monitoring systems in place. Early engagement is critical.
Step 3: Access the CBAM Transitional Registry
All quarterly reports must be submitted via the CBAM Transitional Registry, managed by the European Commission.
How to register:
Registry access: Your NCA grants access. Processing times vary by Member State, so apply early.
Step 4: Complete the Quarterly CBAM Report
The CBAM report consists of three main sections:
Section 1: Header Information
Section 2: CBAM Goods Imported
Section 3: Emissions Data
Data quality matters: The European Commission performs spot checks against customs data. Inconsistencies trigger reviews by your NCA, which may result in penalties.
Step 5: Submit Before the Deadline
Reports are due by the end of the month following each quarter:
|
Reporting Period |
Deadline |
|
Q1 (Jan-Mar) |
30 April |
|
Q2 (Apr-Jun) |
31 July |
|
Q3 (Jul-Sep) |
31 October |
|
Q4 (Oct-Dec) |
31 January (following year) |
Correction window: You can correct submitted reports for up to two months after the deadline. For Q1 and Q2 2024 reports, corrections were allowed until 31 July 2024.
Managing Data Gaps: What If Suppliers Don't Provide Emissions Data?
Option 1: Use Default Values (Transitional Phase)
Until 31 July 2024, importers could use estimation methods without penalty. From August 2024 onwards, default values can still be used, but with limitations:indirect
Option 2: Engage Suppliers Early
Non-compliance from suppliers is a supply chain risk. Importers should:
✅
Include CBAM data requirements in purchase contracts
✅ Offer training
or resources to suppliers on emissions monitoring
✅ Prioritize
suppliers who provide verified emissions data (competitive advantage from 2026)
✅ Consider
alternative suppliers in jurisdictions with established carbon pricing or
monitoring systems
Option 3: Leverage the CBAM Operator Portal (From 2025)
Starting January 2025, non-EU manufacturers can register on the CBAM Operator Portal to report emissions directly to the European Commission. Importers can then reference this centralized data, reducing administrative burden.
Benefit: One supplier report can serve multiple importers, improving data consistency.
Preparing for the Definitive Phase (2026+)
What Changes in 2026?
From 1 January 2026, the CBAM transitions to a financial obligation model:
Action Items for Importers (2025)
|
Action |
Deadline |
Purpose |
|
Finalize supplier agreements with emissions reporting clauses |
Q1 2025 |
Ensure data availability |
|
Conduct supplier audits for emissions monitoring capabilities |
Q2 2025 |
Identify gaps early |
|
Engage accredited verifiers for supplier verification |
Q3 2025 |
Prepare for 2026 requirements |
|
Estimate CBAM certificate costs based on 2024/2025 data |
Q4 2025 |
Budget for 2026 obligations |
Common Pitfalls and How to Avoid Them
Pitfall 1: Incomplete Supplier Data
Risk: Missing production route details or carbon price information triggers NCA reviews.
Solution: Use the European Commission's communication template and conduct quarterly data reviews with suppliers.
Pitfall 2: Inconsistent Reporting Periods
Risk: Supplier uses fiscal year (April-March), but you report by calendar quarters—misalignment leads to errors.
Solution: Agree on a standardized reporting period with suppliers. If different periods are unavoidable, document the methodology clearly in your CBAM report.
Pitfall 3: Ignoring Indirect Emissions
Risk: During the transitional phase, indirect emissions must be reported separately for all CBAM goods*. Omitting them is non-compliance.* Fußnote: Note: From 2026, indirect emissions reporting will be limited to goods listed in Annex II of the CBAM Regulation.
Solution: Always request both direct and indirect emissions from suppliers. Use default electricity emission factors if supplier-specific data is unavailable.
Pitfall 4: Late Submissions
Risk: Each late report incurs penalties (€10-€50/tonne). Repeated violations can escalate to higher fines.
Solution: Set internal deadlines 1-2 weeks before official deadlines. Automate data collection processes where possible.
Actionable Checklist: CBAM Reporting for Importers
Quarterly Tasks:
Annual Tasks (2025):
How WOLQE CBAM Can Help
Managing CBAM reporting across multiple suppliers and product categories is complex. WOLQE CBAM offers:
✅
Supplier Data Management – Centralized platform to collect and validate
emissions data
✅ Quarterly
Reporting Support – Ensure timely and accurate submissions to the CBAM
Registry
✅ Cost
Forecasting Tools – Estimate CBAM certificate liabilities for 2026+
✅ NCA Liaison
Services – Handle communications with your National Competent Authority
Ready to streamline your CBAM reporting? Run the CBAM Checker to assess your compliance status or Request a Free Consultation with our experts.
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For Importers:
For Manufacturers:
Legal Disclaimer
This article is for informational purposes only and does not constitute legal, tax, or regulatory advice. CBAM regulations are subject to updates by the European Commission. Importers should consult the official EU CBAM Regulation (EU) 2023/956, Implementing Regulation (EU) 2023/1773, and seek guidance from qualified legal and compliance advisors.