Starting 2025 Strong: Filing Your Q4-2024 CBAM Report - What you need to focus on how!
As the new year begins, businesses subject to the EU’s Carbon Border Adjustment Mechanism (CBAM) are gearing up for a critical milestone: submitting the Q4-2024 CBAM report, due on 31 January 2025. This report closes the first full year of CBAM’s transitional phase and sets the stage for preparing businesses for the mechanism’s full implementation in 2026.
At Customs Manager Ltd., we understand that navigating CBAM compliance can be complex. Our tailored guidance ensures businesses meet their reporting obligations while building a strong foundation for future compliance.
Why the Q4-2024 Report is Critical
The Q4 report represents more than a regulatory obligation—it’s an opportunity to enhance processes, refine data accuracy, and prepare for the future.
Closing 2024 with Compliance
Filing the Q4 report ensures your business meets the requirements of CBAM’s transitional phase, avoiding compliance risks and penalties.
Insights for 2025
This report provides crucial data on embedded emissions, enabling businesses to forecast their certificate needs and refine cost management strategies.
Foundation for 2026 Obligations
As mandatory certificate procurement begins in 2026, the Q4-2024 report offers a chance to refine frameworks, ensuring readiness for full CBAM implementation.
How to Prepare for the Q4-2024 CBAM Report
Filing the Q4 report requires strategic planning and meticulous attention to detail.
Here are the essential steps to ensure a seamless submission:
1. Stay Informed
CBAM requirements continue to evolve, with frequent updates to regulations and FAQs. Staying informed is crucial for accurate reporting. Regularly review the European Commission’s latest CBAM guidance. Consult Customs Manager Ltd.’s CBAM experts for clarity and tailored advice if in doubt.
Top Tip: Leave your email address at www.customsmanager.info to receive Trade Intelligence Updates on CBAM directly into your inbox.
Collect and Verify Supplier Data
Accurate supplier data is the cornerstone of CBAM reporting, making early engagement essential. Collaborate with suppliers to collect emissions data well in advance and verify its accuracy to avoid last-minute discrepancies. We have designed a workshop on how to effectively communicate with suppliers. Please see www.customsmanager.org/events for details.
The "Effective CBAM Supplier Communication Workshop" is a four-hour public hands-on workshop in which participants design an effective communication and information strategy for their overseas suppliers of CBAM goods. By the end of this workshop, you will walk away with your self-designed strategy for communicating effectively with suppliers on your exact CBAM requirements. Explore best-practice communication strategies and effective methods to pass information and knowledge to suppliers to convince them to supply you with the correct CBAM information.
Find out more here
Optimise Internal Processes
Robust compliance frameworks guarantee efficient and accurate reporting. We suggest aligning CBAM reporting processes with best practices, such as Administrative Organisation and Internal Control (AOIC) frameworks. An AO description outlines the authorisations, regulations, and procedures that form the administrative process framework. The internal control setup is defined within the AO, detailing the allocation of tasks and the necessary segregation of duties among decision-making, implementation, and record-keeping. A strong AO is particularly beneficial for CBAM as it ensures the availability of accurate information at the right time. An AO description is not a static document; it requires regular updates. This enables the executive board and daily management to effectively control and manage the organisation. With over 20 years of experience in drafting AO descriptions, we can guide you through this process. Our experts can help tailor these processes to meet CBAM’s specific needs.
4. Pre-File the CBAM report at least a week before the deadline
Pre-submission checks help reduce errors and ensure regulatory compliance. They should be done with the deadline in mind. Perform a detailed review of your Q4 report, addressing any issues before submission. If you wish to understand how to complete the CBAM report, we recommend joining out CBAM Report Filing workshop.
CBAM Report Filing (Workshop)
Join us for this four-hour virtual online workshop on successfully filing the CBAM report to the EU Commission. This is a workshop for EU importers of CBAM goods and their indirect representatives or agents filling on their behalf.
Lessons Learned from 2024
Reflecting on the first full year of CBAM compliance, here is what I think is the most important to focus on in 2025:
Supplier Collaboration is Crucial: Early and clear communication with suppliers simplifies data collection and improves accuracy. Please consider joining our workshop on effective supplier communication.
Plan Ahead: Businesses that began preparations early experienced fewer challenges and avoided last-minute stress.
Refine Frameworks Continuously: Each quarterly report is an opportunity to strengthen processes and enhance compliance readiness.
Looking Ahead: CBAM in 2025
While the Q4-2024 report is a significant milestone, the journey doesn’t end there. Businesses should focus on these priorities for 2025:
1. Preparing for CBAM Authorised Declarant Status
Starting in early 2025, CBAM declarants can seek the status of ‘authorised CBAM declarant’ through the CBAM Registry. The National Competent Authority of the EU Member State, where the declarant is based, will review applications. This status will be required from 1 January 2026 for importing CBAM goods into the EU customs area. The draft implementing regulation highlights the necessity of strong compliance frameworks to manage CBAM risks for becoming a CBAM Authorised Declarant. Consider revising internal processes and documentation, such as AOIC frameworks, with assistance from Customs Manager Ltd.’s CBAM experts. You can schedule a free call with your CBAM expert on www.customsmanager.org
Changes to the CBAM registry: Streamlined Data Sharing for Non-EU Operators
From 1 January 2025, the CBAM Registry will feature a new portal section enabling non-EU installation operators to upload and share their installation and emissions data directly with reporting declarants. This centralised system eliminates the need to submit data separately to each declarant. Detailed guidance can be found under “CBAM Registry access for non-EU installation operators.” (See below)
3. Strengthening Supplier Engagement
Enhancing relationships with suppliers will simplify data collection and reporting for future compliance, potentially involving an outreach strategy. Our "Effective CBAM Supplier Communication Workshop" is a four-hour interactive public workshop where participants develop a successful communication and information strategy for their overseas suppliers of CBAM goods.
Investing in Training and Expertise
As CBAM evolves, regular training ensures internal teams and suppliers remain equipped to meet regulatory demands. Rely on Customs Manager Ltd. for tailored training programs and expert advice to navigate CBAM’s complexities with our life fundamental training:
CBAM Live Fundamentals Training
Unlock expertise in the EU's Carbon Border Adjustment Mechanism (CBAM) with our live online 4-hour course. Master CBAM’s essentials, compliance steps, and critical terms. Perfect for customs managers, import/export pros, and more. Join us online—book now! https://www.customsmanager.org/events
This training is also available on demand and includes the four hours live training - recorded. Don't wait for the new training; download your CBAM live on-demand training now.
CBAM 2025 Support Bundle - Instant Download
We held a one-hour update webinar recently on CBAM, reviewing the latest developments. You can download the CBAM 2025 Support Bundle right now and download:
Recording of this webinar
Slides of this webinar
CBAM Legislation: Regulation & Implementing Regulation
CBAM Self-Assessment Tool
CBAM’s latest FAQ document answering more than 100 questions
Information sheets for non-EU producers per CBAM group
Information sheets for EU Importers per CBAM group
CBAM communication template for installations
Examples of the communication template filled
Guidance for Non-EU-Installation Operators on CBAM
Guidance document on CBAM implementation for importers of goods into the EU
Default values for the transitional period
Default values for the transitional period (Excel format)
Provisional list of National Competent Authorities (NCAs)
Transitional CBAM Registry user manual for Declarants
Most important features for the Declarant Portal for release CBAM 1.3.1.0
Guidance for declarants on “Request Delayed Submission”
Draft law concerning conditions and procedures related to the status of authorised CBAM declarant + Annex
Your Trusted Partner for CBAM Compliance
Navigating CBAM can be daunting, but Customs Manager Ltd. specializes in providing businesses with personalized support to ensure seamless compliance. From refining processes to assisting with data validation and strategic planning, our experts offer practical solutions tailored to your needs. Let Customs Manager Ltd. be your partner in meeting the Q4-2024 deadline and preparing for a successful year of CBAM compliance in 2025. Book a free call with your CBAM expert.
Expert CBAM Webinar "Preparing for the Definite Period"
Join us for this expert webinar as we discuss how to prepare for the Definitive Period of CBAM in 2026. We will look at the new laws and regulations concerning the "Authorized CBAM Declarant Status," third-party verifiers, CBAM certificates and their costs, and possible simplifications. Please register here. Note that PREMIUM members of our Trade Intelligence Service can join for free.
Conclusion
The Q4-2024 CBAM report is more than a regulatory requirement—it’s a stepping stone toward success under the evolving CBAM framework. By staying informed, engaging suppliers, and consulting with experts, businesses can ensure a smooth submission process while building a strong foundation for the years ahead. At Customs Manager Ltd., we’re here to support your compliance journey, offering expert insights and tailored solutions to make 2025 your most successful year under CBAM yet!
Here’s to a compliant and prosperous new year!
🎓 Learn About the EU CBAM
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📌 Advice, Guidance & Thought Leadership on
EU CBAM
🛠️ Practical Tools for EU CBAM Implementation
⬇️Transitional CBAM Registry user manual for Declarants as of 01 October 2024
⬇️ Most critical features for the Declarant Portal for release CBAM 1.3.1.0
⬇️ CBAM - Guidance for declarants - “Request Delayed Submission”
⬇️ CBAM Quarterly Report sample file for importers as of 01 October 2024
⬇️ CBAM Quarterly Report structure (XLS format) as of 01 October 2024
⬇️ Sector-specific factsheets updated as of October 31, 2024 (information for non-EU producers of cement, aluminium, fertilisers, iron and steel, hydrogen, and electricity).
⬇️ Sector-specific factsheets updated as of October 31, 2024 (information for EU importers of cement producers, aluminium, fertilisers, iron and steel, hydrogen, and electricity).
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