compliance e AEO

CBAM rules of application, reporting obligation and transitional period: a short check of the draft

It is available 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…”.

This document lays down that Each reporting declarant shall provide the following information:

  • the quantity of the goods imported, expressed in megawatt hours for electricity and in tonnes for other goods;
  • the type of goods as identified by their CN code.,
  • the country of origin of the imported goods;
  • the installation where it was produced, identified by the following data: the applicable United Nations Code for Trade and Transport Location (UN/LOCODE) of the location; the applicable United Nations Code for Trade and Transport Location (UN/LOCODE) of the location; geographical coordinates of the main emission source of the installation
  • the production routes used, which shall reflect the technological option for the production of the goods, and information on specific parameters qualifying the indicated production route chosen;
  • the descriptive parameters that have an effect on the embedded emissions;
  • for steel goods, the identification number of the specific steel mill where a particular batch of raw materials came from, where known;
  • the specific direct emissions of the goods, which shall be determined by converting the attributed embedded direct emissions of the production processes into emissions specific of the goods defined as CO2e per tonne;

For indirect emissions, each reporting declarant shall in addition report the following information in the CBAM reports:

  • electricity consumption;
  • the indication whether the declarant reports actual emissions or default values;
  • the corresponding emissions factor;
  • the amount of specific indirect emissions.

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.