Carbon tax - first CBAM reports by 31 January 2024

CBAM - first reporting for importers

On 1 October 2023, the regulations on the EU's CO2-inclusive border price adjustment mechanism, the 'Cross-Border Adjustment Mechanism', or CBAM in short, came into force. The new obligations under EU Commission Implementing Regulations 2023/1773 and 2023/956 apply to importers who import the following groups of goods into the EU:

• Electricity,
• Cement,
• Fertilisers,
• Cast iron and steel,
• Hydrogen,
• Aluminium.

Entities importing the aforementioned groups of goods and goods derivative will soon face new obligations, including:

• The necessity to collect data on producers of imported goods and manufacturing sites,
• The necessity to establish so-called embedded emissions on imported goods,
• The necessity to keep CBAM records on imported goods,
• Quarterly reporting of CBAM declarations,
• Obligation to communicate with authorised CBAM authorities - in Poland, the National Balancing and Emissions Management Centre is responsible for CBAM proceedings.

Learn more about the new obligations: CBAM - new obligations for importers as from 1 October

CBAM obligations - fines for failure to report emissions

Any failure to comply with CBAM obligations for obliged entities could mean severe sanctions. Under the legislation, importers who fail to comply with the new obligations to report imports of high-carbon commodities could face fines of between €10 and €50 per tonne of unreported emissions.

It is also worth noting that a lot of the data collected under CBAM often comes from third-country suppliers. Without establishing how information is collected and shared with suppliers, the new obligations may be impossible to meet.

Learn more about CBAM: CBAM – the customs revolution in Europe

CBAM reporting - find out how we can help

In response to your needs in meeting the new CBAM regulation obligations, we have developed a service - CBAM reporting outsourcing.

We offer full support regarding CBAM obligations:

• We identify the goods covered by the new obligations,
• We indicate which obligations arise from importing these goods,
• We prepare instructions for third country suppliers on their obligations and the scope of data to be provided,
• We prepare a database to collect information for reports,
• We maintain CBAM records,
• We prepare quarterly CBAM reports,
• We provide ongoing support and advisory on implementing the obligations.