Filing CBAM reports WITHOUT default values? Key recommendations for emissions reporting after 1 August 2024.
What Questions We Will Answer in this Blog:
What are the new requirements for reporting emissions under CBAM after 1 August 2024?
How can businesses document their efforts to obtain actual emissions' data?
What are the implications of using standard values instead of actual emissions data?
Introduction:
As of 1 August 2024, significant changes have occurred in the reporting requirements for the Carbon Border Adjustment Mechanism (CBAM). Importers of specific carbon-intensive goods into the European Union (EU) must now provide actual emissions data, rather than relying on standard values. These changes are crucial for customs and import professionals to ensure compliance and avoid potential penalties. Understanding these updates is essential for maintaining smooth import operations and adhering to the latest EU regulations.
Abbreviations We Use in this Blog:
To facilitate understanding, here are the key abbreviations we use:
CBAM is the Carbon Border Adjustment Mechanism, an EU policy that aims to reduce carbon emissions by placing a carbon price on imports.
DEHSt: Deutsche Emissionshandelsstelle, the German Emissions Trading Authority, is responsible for overseeing CBAM compliance.
EU: European Union.
What are the New Requirements for Reporting Emissions under CBAM?
Since 1 August 2024, importers subject to CBAM must report the actual emissions associated with their imported goods. This shift marks the end of the previous allowance to use standard values for quarterly reports. The primary goal is to provide a more accurate reflection of the carbon footprint of imported goods, aligning with the EU's broader environmental objectives.
The reporting process now requires importers to gather and verify precise data on direct and indirect emissions from their supply chains. This data must be included in the CBAM reports, submitted quarterly to the national CBAM authority, like the German DEHSt or any other national authority in the EU. The new rules mandate that businesses show diligence in obtaining this information from suppliers or manufacturers.
How Can Businesses Document Their Efforts to Obtain Actual Emissions Data?
If obtaining actual emissions data proves challenging, companies must document their efforts thoroughly. The CBAM Transition Register, an electronic database managed by the European Commission, plays a crucial role in this documentation process.
In cases where actual emissions data cannot be reported, companies must demonstrate that they have exhausted all reasonable avenues to obtain this data.
This includes:
Reaching out to suppliers and manufacturers for emissions data.
Documenting all communication and efforts made in the CBAM Transition Register.
Utilising the "Comments" field in the CBAM portal to provide evidence of attempts and any obstacles encountered.
By meticulously documenting these efforts, companies may still use standard values if the DEHSt deems the situation justifiable.
What are the Implications of Using Default Values Instead of Actual Emissions Data?
The use of Default values is now significantly restricted. However, under certain circumstances, the DEHSt or another EU Member State National Authority may allow their use if the importer can prove that obtaining actual emissions data was not feasible without disproportionate effort.
The DEHSt, as an example, will consider several factors, including:
Proportionality of Effort: Whether the effort to obtain actual data was reasonable given the potential environmental impact.
Accuracy of Reporting: Whether the standard values used closely approximate the expected actual emissions.
Documentation: The completeness and accuracy of the documentation provided in the CBAM Transition Register.
It’s essential to note that even when standard values are used, the DEHSt or other national authorities can request additional information or clarification. Failure to comply with these requests could lead to penalties or further scrutiny.
Conclusion:
The recent changes in CBAM reporting requirements underscore the EU's commitment to accurate emissions reporting. To remain compliant, importers must now focus on obtaining actual emissions' data. Thorough documentation in the CBAM Transition Register is critical, mainly when standard values are used. We are ready to support you with this.
Expert Recommendations:
Collect Data Early: Gather emissions data well before the reporting deadline.
Document Everything: Keep a detailed record of all attempts to obtain emissions data.
Seek Training: Ensure your team is up-to-date on the latest CBAM compliance requirements.
How We Can Help:
🌍 Customs Manager Ltd offers comprehensive support for CBAM compliance. We assist with every aspect of import-export operations, including bespoke consultancy and practical assistance.
Our services include:
Import-export operations and compliance consultancy
Public, in-house, and on-demand training for customs professionals
Weekly customs trade intelligence and updates
UK import and export customs clearance services
For more details, visit www.customsmanager.org.
Sources That We Base Our Information in This Blog On
This blog is based on the latest updates from the European Commission, the DEHSt guidelines, and relevant legal frameworks under the CBAM regulation.
Where to Find More Information on CBAM
To dive deeper into CBAM compliance and related legal frameworks, consider these resources:
You can also:
Subscribe to The Customs Watch – our weekly consolidation of law, guidance, and policy updates.
Visit our Knowledge Hub Content Library at www.customsmanager.info for more on CBAM.
Search our library for any topic here: Search Results.
If you're new here, get started with a free Standard Membership to receive updates directly to your inbox. Leave your e-mail at www.customsmanager.info
Top Tips for CBAM Management 2025 (Webinar)
07 Nov 2024, 10:00 – 11:00 GMT
Afterwards, on-demand at www.customsmanager.org/shop
Virtual Event Using Zoom
Top Tips in Managing the Carbon Border Adjustment Mechanism (CBAM) in 2025
Training
We offer extensive training on CBAM and related topics:
Various Dates
Virtual Event Using Zoom
Join us for this four-hour virtual online workshop on successfully filing the CBAM report to the EU Commission. This workshop is for EU importers of CBAM goods and their indirect representatives or agents who are filing on their behalf.
20 Sept 2024, 09:00 – 13:00 BST
Virtual Event Using Zoom
Join us for this four-hour hands-on virtual online workshop. Design the perfect communication and information strategy to convince your overseas suppliers to provide accurate, complete and timely CO2e data for your CBAM report.
Visit www.customsmanager.org/events to explore our course plan and book your spot.
Disclaimer
This blog is for educational purposes only and should not be considered legal advice. You should consult legal professionals or specialists on compliance requirements and guidance. Book a free call with our expert at Customs Manager Ltd.
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