• compliance e AEO

    CBAM and penalties

    The article 16 of the document draft Ares(2023)4079551 will provide the cases where a penalty is imposed  “…(a) the reporting declarant has not taken the necessary steps to comply with the obligation to submit a CBAM report, or   (b) the reporting declarant has not taken the necessary steps to correct the CBAM report to comply with the obligations…”. The amount of the penalty, for each tonne of unreported embedded emissions shall be between EUR 10 and EUR 50. Moreover, the penalty can increase in accordance with the European index of consumer prices; in parallel, the national competent authorities may determine the exact amount based on the following criteria: “…(a)            the…

  • compliance e AEO

    CBAM and carbon price paid

    The reporting declarant has to provide in the CBAM report the following information regarding the carbon price paid in a country of origin for the embedded emissions: (a)     form of carbon price; (b)     the country of origin; (c)     any rebate or other form of compensation available in the country that would have resulted in a reduction of that carbon price; (d)     indication of the provision of a legal act providing for the carbon price, rebate, or other forms of relevant compensation, including a copy of the provision; (e)     type of product indicated by CN code; (f)     quantity of embedded emissions covered by the carbon price; (g)     quantity of embedded emissions…

  • Uncategorized

    CBAM, inward processing relief and CBAM report

    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…” lays down the following data about the goods placed under inward processing (Article 257 of UCC) must be contained in the CBAM report:  “…  (a) the quantities of goods listed in Annex I to Regulation (EU) 2023/956 that have been released for free circulation following inward processing during that period;  (b)  embedded emissions corresponding to these quantities of goods listed in Annex I to Regulation (EU) 2023/956…

  • compliance e AEO

    CBAM: how calculate the emission

    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…

  • 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…

  • compliance e AEO,  valore in dogana

    Customs classification, parts and European Court of Justice

    The European Court of Justice Chamber X with case n.725/21 of 9.03.2023 , stated that: in the customs nomenclature there is not a definition of ‘part’ ; part does not cover items which are not indispensable, for the completed good, to fulfil its function. It is useful to share the following points of the judgement: “….in accordance with General Rule 1 for the interpretation of the CN, the tariff classification of goods is determined according to the terms of the headings and section or chapter notes of that nomenclature. In the interests of legal certainty and ease of control, the decisive criterion for the tariff classification of those goods must…

  • circular economy,  compliance e AEO

    CBAM, customs classification and HS code

    Which are the goods covered by the CBAM? The Annex I of the regulation (proposal) lists the main categories of goods with the HS codes and the greenhouses gases related. The list, below summarized, recalls the main role played by the customs classification which is one of the three pillars (with value and origin) of the customs obligation. In other words, we have to take care of our classification becuase: a) we risk infrigement of CBAM rules; b) reduce our “reliability” (if AEO). We have to: a) monitor the internal process of customs classification; b) check the customs  classification made in our behalf by other entities; c)  discrepancies and audit…