The draft [Document Ares(2023)4079551] of a regulation “…laying down the rules for the application of Regulation (EU) 2023/956 of the European Parliament and of the Council as regards reporting obligations for the purposes of the carbon border adjustment mechanism during the transitional period…” states that the level of embedded emissions has to be calculated using one of the following methods:
(a) determining emissions from source streams on the basis of activity data obtained by means of measurement systems and additional parameters from laboratory analyses or standard values;
(b) determining emissions from emission sources by means of continuous measurement of the concentration of the relevant greenhouse gas in the flue gas and of the flue‑gas flow.
The derogations are:
- a) 12.2024: “…By way of derogation from paragraph 1, until 31 December 2024, the level of embedded emissions may be calculated using one of the following methods, if they lead to similar coverage and accuracy of emissions data compared to the methods listed in that paragraph:
- methods used under monitoring, reporting and verification systems (MRV);
- other methods, with any of the following applicable monitoring rules:
a carbon pricing scheme where the installation is located;
an emission monitoring scheme at the installation which can include verification by an accredited verifier; or
compulsory emission monitoring schemes.
- b) 07.2024: “…By way of derogation from paragraph 1 and 2 until 31 July 2024 for each import of goods for which the reporting declarant does not have all the information listed in Article 3(2), the reporting declarant may use other methods for determining the direct emissions. In such case the reporting declarant shall indicate and reference in its CBAM report the methodology followed to establish such values…”.
The trade compliance obligations related to CBAM require the AEO approach: monitoring of internal processes, reporting, KPI, high knowledge of the customs regulations, ongoing risk assessment. The AEO authorization is based on the following pillars: classification, value and origin. These areas are monitored from the self assessment questionnaire.