CBAM reporting

CBAM reporting, an obligation under EU climate policy

The EU is implementing a number of measures for a climate-sustainable Europe. A key initiative in this respect is the European Green Deal. One of its mechanisms is the Carbon Border Adjustment Mechanism (CBAM), a mechanism for adjusting border prices for CO2 emissions.

Under CBAM, traders introducing certain goods into the EU will be required to purchase emission certificates and submit CBAM declarations. The legal basis is Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 and Commission Implementing Regulation (EU) 2023/1773 of 17 August 2023 clarifying reporting obligations during the CBAM transition period.

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

CBAM - reporting during the transition period

Before the acquisition of CBAM emission certificates becomes mandatory (1 January 2026), between 2024 and 2025, the obligations of selected importers are to be limited to annual CBAM reporting. There is a so-called transition period from 1 October 2023 to 31 December 2025.

During the transition period, importers importing products covered by the regulations are required to report the total embedded greenhouse gas emissions of these goods. Such commodities include inter alia cement, iron and steel, aluminium, fertilisers and electricity.

The first CBAM declarations shall be submitted for Q4 2023 by the end of January 2024. In principle, CBAM declarations are to be submitted by the end of the month following the quarter in which the goods to be reported were imported.

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

CBAM reporting - support for businesses covered by the new obligation

CBAM is mainly a new obligation for many traders, importers or indirect customs representatives. Although the customs authorities are to inform taxpayers of the reporting obligation during the transition period, the first reports must be submitted quite soon, by 31 January 2024 for goods imported in the fourth quarter of 2023.

CBAM is mainly a new obligation for many traders, importers or indirect customs representatives. Although the customs authorities are to inform taxpayers of the reporting obligation during the transition period, the first reports must be submitted quite soon, by 31 January 2024 for goods imported in the fourth quarter of 2023. Learn more: Carbon tax - first CBAM reports by 31 January 2024

We have developed a comprehensive support service for you regarding compliance with EU CBAM requirements. Our assistance includes a range of activities aimed at both preparing your organisation for the new obligations and meeting them during the transition period and once the full regulation is implemented and the provisions for purchasing CBAM certificates come into force.

Joining the experience and expertise of our multi-area experts, we offer comprehensive support to companies subject to CBAM reporting.

CBAM reporting - how can we help?

CBAM reporting - the scope of Crowe's services:

Determining the products covered by CBAM

Preparation of a concise memorandum on the products to be reported according to the list of goods provided with the assigned CN nomenclature codes (depending on the number of categories of goods).

Analysis of obligations in CBAM for importers

Preparation of a tax manual on obligations relating to the importation of goods into the customs territory of the European Union:

• Summary of obligations for reporting emissions from the production of products covered by CBAM,
• Description of the reporting process,
• Indication of necessary data from suppliers,
• Description of the necessary processes to be implemented during the CBAM transition period,
• Shape of CBAM records and requirements for their maintenance,
• Indication of reporting methods,
• Scope of CBAM reports,
• CBAM administrative proceedings - procedure to call for correction,
• CBAM sanctions,
• Information on obligations in the CBAM target system.

Analysis of obligations in CBAM for non-EU suppliers

Preparation of a tax memorandum on the obligations of non-EU suppliers to export goods into the customs territory of the European Union, including:

• Summary of reporting obligations for emissions from the production of steel and aluminium products,
• Data covered by the emissions monitoring system,
• Description of reporting methods,
• Indication of production processes covered by emission monitoring,
• Description of the method and instructions for monitoring emissions according to Commission CPR (EU) 2023/1773,
• Preparation of a database in .accdb or. xslx for emission measurement, according to the European Commission's draft CBAM communication template for installations.

CBAM Hotline

We offer ongoing support, which provides convenient access to our experts for a fixed number of hours per month.

Keeping CBAM records until March 2024

Includes keeping CBAM records based on data from importers and suppliers according to Commission Implementing Regulation (EU) 2023/1773 of 17 August 2023.

CBAM reporting

Ongoing quarterly CBAM reporting on the UUM&DS CBAM portal after submission of the first two reports.

CBAM proceedings

Support for proceedings conducted by the National Balancing and Emissions Management Centre concerning the procedures set out in Commission Implementing Regulation (EU) 2023/1773 of 17 August 2023, in particular concerning corrections and adjustments to CBAM reports.

See also: CBAM - support for customs agencies