CBAM and AEO: the workflow to comply with

The  Guidance document on CBAM implementation for importers of goods into the EU shares the following workflow aiming to simply the operational aspects of the CBAM compliance:

1. The importer (reporting declarant) receives CBAM goods from various installations, possibly from different countries outside the EU.
2. For each import, the importer lodges the usual customs declaration. The customs authority of the relevant EU Member State checks and clears the import, as usual.
3. The customs authority (or the IT system used) informs the European Commission (using the CBAM Transitional Registry) of this import. This information can then be used to check the completeness and accuracy of quarterly CBAM reports.
4. The reporting declarant requests the relevant data on specific embedded emissions of the imported CBAM goods from the operators (in practice, this may involve intermediary traders, who would have to forward the request to the operator of the installation which produced the CBAM goods). The latter reply by sending the requested data, if possible using the template provided for this purpose by the Commission. The data may be voluntarily verified by a third-party verifier.
5. The reporting declarant is then able to submit the quarterly CBAM report to the CBAM Transitional Registry. 6. An information exchange between the Commission and the competent authorities in the EU Member States takes place. The Commission informs (based on the customs data), which reporting declarants are expected to submit CBAM reports. Furthermore, the Commission can perform spot checks of actual reports and check their completeness with regards to the customs data. Where irregularities are identified, the Commission informs the competent authority of this.

The competent authority will then follow up, usually by getting in contact with the importer and Importer (reporting declarant) European Commission CBAM Transitional Registry. If the reporting declarant does not correct the mistakes, the competent authority can ultimately impose a (financial) penalty.

7. to avoid similar problems in the future, the importer who received a penalty should inform the operator of the problem(s) identified by the Commission or the competent authority in order to address the issue(s) for future submissions.

Finally, it is important to notice that the mentioned workflow can be token into consideration for:

1. implementing internal customs procedures;
2. monitoring of the procedures;
3. risks assessment of the internal processes.

In other words, the CBAM implies an array of obligations manageable by the AEO (trust & check) operators.