CBAM: what needs to be reported by reporting declarants

During the transitional period, importers need to report on a quarterly basis the embedded emissions in goods imported during that quarter of a calendar year, detailing direct and indirect emissions as well as any carbon price effectively due abroad.

The following information must be reported by importers in the CBAM report:

• The total quantity of each type of goods, expressed in megawatt hours (MWh) for electricity and in tonnes for other goods, specified per installation producing the goods in the country of origin (made in);
• The actual total embedded emissions, expressed in tonnes of CO2e emissions per MWh of electricity or for other goods in tonnes of CO2e emissions per tonne of each type of goods;
• The total indirect emissions, including amount of electricity consumed and the applicable emissions factor; • The carbon price due in a country of origin for the embedded emissions in the imported goods, taking into account relevant rebates or other forms of compensation. In order to obtain this information, it is imperative to have a clear procedures in place for monitoring imports.

The Guidance document on CBAM implementation for importers of goods into the EU Suggests to include:

1. If the customs code code of the good being imported falls within the list of goods given by Annex I to the CBAM Regulation, the reporting obligation under the CBAM has to be triggered. The most efficient way for importers to handle the CBAM might be to install a tool which generates a list of all imported goods falling under the carbon border adjustment mechanism. A software could support the importers in managing this topic.
2. The importer could also make the disclosure of information a dedicated clause in the purchase contract with the producer of the goods imported.