Strict CBAM reporting is now mandatory. Starting Q3 2024, standard CO2 values may cover only 20% for complex goods.
What Questions We Will Answer in this blog:
What are the latest requirements for CBAM compliance?
How can you ensure accurate CBAM reporting?
What are the consequences of non-compliance?
Introduction
CBAM (Carbon Border Adjustment Mechanism) is no longer a theoretical concept. As of Q3 2024, strict reporting rules are in force, meaning companies must accurately report CO2 emissions on imports or face fines. Understanding these new requirements is crucial for customs, import, and export professionals to avoid penalties and maintain compliance.
"Attention to detail and early preparation are key to avoiding costly mistakes with CBAM." – Arne Mielken, Managing Director of Customs Manager Ltd.
Abbreviations We Use in this Blog
CBAM – Carbon Border Adjustment Mechanism
CO2 – Carbon Dioxide
Q3 2024 – Third quarter of 2024
What are the latest requirements for CBAM compliance?
Starting from Q3 2024, the reporting landscape for the Carbon Border Adjustment Mechanism has changed. Previously, companies were allowed to use rtificially set CO2 values during the initial rollout phase of CBAM. However, that leeway is gone, and stricter guidelines now apply.
Stricter Reporting Rules
Under the updated regulations, companies can only use standard values for up to 20% of their total embodied emissions for complex goods. Accurate and verifiable data must account for the remaining 80%. This is in line with Article 5 of Regulation (EU) 2023/1773, which mandates that businesses provide real, measurable CO2 emission data from both direct and indirect emissions per tonne of imported product.
This shift is significant. It means your suppliers must now deliver detailed emission data, and you must ensure your reporting reflects these figures accurately.
Examples of Data You’ll need:
Direct emissions from the production of imported goods
Indirect emissions from energy use in manufacturing
Emission data certified under ISO 14067:2018 or equivalent methods
For complex goods, the obligation to supply accurate data can be daunting, but the consequences of ignoring this requirement are far worse.
How can you ensure accurate CBAM reporting?
The transition to stricter reporting may seem overwhelming, but breaking the process down into manageable steps can help ensure compliance.
Obtain the Correct Data
The first step is gathering the correct emission data from your suppliers. This isn’t just about a simple request – it’s about formalizing the process to ensure accountability. Work closely with your purchasing, CSR, import, and customs teams to facilitate this collaboration.
Practical steps
Formalize requests for data using a supplier communication template.
Follow up with suppliers and provide clear instructions to installation operators on data submission.
Collect data in a structured format, such as the "Summary Communication" section of the CBAM template.
If suppliers struggle with providing accurate data, offer guidance or alternatives. But don’t let incomplete data slide – ensuring data accuracy is essential to avoid the fines we’ll discuss below.
Organize Your Reporting Process
CBAM reporting involves meticulous organization. You’ll need to identify imports subject to CBAM based on customs data, including weight, manufacturing locations, and emissions by origin and customs code. This is particularly relevant if you’re dealing with multiple suppliers or factories. Take special care to distinguish between different customs regimes. Each needs to be reported separately, so attention to detail is paramount.
What are the consequences of non-compliance?
The consequences for failing to meet CBAM’s strict reporting rules can be severe. The European Commission’s CBAM regulations outline specific penalties for missing deadlines or submitting incomplete or inaccurate data.
Fines for Violations
Under Article 16 of the CBAM Implementing Regulation, penalties can range between €10 and €50 per tonne of unreported emissions. If you’re importing thousands of tonnes of covered goods, the fines can quickly skyrocket into the tens of thousands of euros.
Missing deadlines or submitting inaccurate reports can also damage your reputation as a reliable partner in the global trade network. No one wants to be known for careless compliance management.
Important takeaways
Fines are steep, ranging from €10 to €50 per tonne of unreported emissions.
Ensure reports are submitted on time to avoid financial and reputational harm.
Adapt to the New Reality
The move from lenient reporting (Q4 2023–Q2 2024) to this stricter regime means adaptability is essential. Businesses that haven’t adjusted yet are now playing catch-up. The key to survival is preparation and collaboration across teams, ensuring data accuracy every step of the way.
Free CBAM Webinar
Join us on Thursday, 07 November for a free webinar on managing the Carbon Border Adjustment Mechanism (CBAM) in 2025. Learn valuable tips and insights to help ensure your business stays compliant with upcoming CBAM regulations. This virtual event will take place via Zoom, offering a convenient way to understand and prepare for the evolving carbon management landscape.
Register now to secure your spot!
Event Details:
Date: Thursday, 07 November
Location: Virtual (Zoom)
Topic: Top Tips for CBAM Management 2025
Don't miss out on this crucial session to stay ahead in CBAM compliance!
Arne’s Takeaway:
CBAM is no longer something to prepare for—it’s here. The shift from default values to real emission data marks a critical turning point for all businesses involved in importing goods subject to CBAM. The stakes are high, but with the right systems in place, you can navigate these new waters with confidence. Focus on collaboration, data accuracy, and timely submissions to avoid costly penalties.
Expert Recommendations:
Formalize communication with your suppliers to ensure they provide accurate emission data.
Collaborate with internal teams, including CSR, purchasing, and customs, to streamline your reporting process.
Prioritize accurate data over convenience – the fines for incomplete reports are significant.
Review all CBAM reporting deadlines to avoid costly penalties.
How My Team and I Can Help
My team and I, along with our enthusiastic specialists, offer comprehensive support for CBAM reporting. We provide hands-on assistance in ensuring your data is accurate, collaborate with your suppliers, and help streamline your reporting processes. In addition, we offer bespoke consultancy services and practical training tailored for customs professionals, importers, and exporters. Our membership services include regular updates on customs and trade developments to keep you informed.
To learn more about how we can support your CBAM compliance efforts, visit www.customsmanager.org.
Sources That We Base Our Information In This Blog On:
Regulation (EU) 2023/1773
CBAM Implementing Regulation (Article 16)
European Commission's Guidance on CBAM
Where to Find More Information On CBAM
Subscribe to The Customs Watch for weekly updates on customs regulations.
Visit our Knowledge Hub at www.customsmanager.info for in-depth articles on CBAM.
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Learn With Me
My team and I offer extensive training on CBAM and other customs-related topics. Visit www.customsmanager.org/events to explore our course offerings and book a public course today.
About the Author
I, Arne Mielken, am a customs, export control, and sanctions expert with over 20 years of experience. As the Managing Director of Customs Manager Ltd, I work with businesses to ensure compliance and efficient customs processes.
Disclaimer: The information provided in this blog post is for educational purposes only. Consult legal professionals for specific compliance guidance.
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