EU Importers
The EU Reporting Declarant
The EU Reporting Declarant is the party obliged to submit the CBAM quarterly reports to the EU Commission. The EU Reporting Declarant can be either the EU importer or the Indirect Customs Representative.
The importer who lodges a customs declaration for release for free circulation of goods in its own name and on its own behalf.
Or
The person, holding an authorisation to lodge a customs declaration referred to in Article 182 (1) of the Union Customs Code (UCC), who declares the importation of goods.
If the importer is not established in an EU Member State, the indirect customs representative must act as the EU Reporting Declarant.
If the importer is established in the EU, the indirect customs representative will only act as EU Reporting Declarant if it has agreed to the reporting obligations in accordance with Article 32 of the CBAM Regulation.
I’m an EU Reporting Declarant. What should I do next?
Let's take it one step at a time.
1. Identify your imported CBAM goods
Calcined Clay
2507 00 80 – Other kaolinic clays
Cement clinker
2523 10 00 – Cement clinkers
Cement
2523 21 00 – White Portland cement, whether or not artificially coloured
2523 29 00 – Other Portland cement
2523 90 00 – Other hydraulic cements
Aluminous Cement
2523 30 00 – Aluminous cement
Unwrought aluminium
7601 – Unwrought Aluminium
Aluminium products
7603 – Aluminium powders and flakes
7604 – Aluminium bars, rods and profiles
7605 – Aluminium wire
7606 – Aluminium plates, sheets and strip, of a thickness exceeding 0,2 mm
7607 – Aluminium foil (whether or not printed or backed with paper, paper-board, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0,2 mm
7608 – Aluminium tubes and pipes
7609 00 00 – Aluminium tube or pipe fittings (for example, couplings, elbows, sleeves)
7610 – Aluminium structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns); aluminium plates, rods, profiles, tubes and the like, prepared for use in structures
7611 00 00 – Aluminium reservoirs, tanks, vats and similar containers, for any material (other than compressed or liquefied gas), of a capacity exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
7612 – Aluminium casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), for any material (other than compressed or liquefied gas), of a capacity not exceeding 300 litres, whether or not lined or heat- insulated, but not fitted with mechanical or thermal equipment
7613 00 00 – Aluminium containers for compressed or liquefied gas
7614 – Stranded wire, cables, plaited bands and the like, of aluminium, not electrically insulated
7616 – Other articles of aluminium
Sintered Ore
2601 12 00 – Agglomerated iron ores and concentrates, other than roasted iron pyrites
Pig Iron
7201 – Pig iron and spiegeleisen in pigs, blocks, or other primary forms – Some products under 7205 (Granules and powders, of pig iron, spiegeleisen, iron, or steel) may be covered here
Some products under 7205 (Granules and powders, of pig iron, spiegeleisen, iron, or steel) may be covered here
Ferro-alloy: FeMn
7202 1 – Ferro-manganese
Ferro-alloy: FeCr
7202 4 – Ferro-chromium
Ferro-alloy: FeNi
7202 6 – Ferro-nickel
DRI
7203 – Ferrous products obtained by direct reduction of iron ore and other spongy ferrous products
Crude Steel
7206 – Iron and non-alloy steel in ingots or other primary forms (excluding iron of heading 7203)
7207 – Semi-finished products of iron or non-alloy steel
7218 – Stainless steel in ingots or other primary forms; semi- finished products of stainless steel
7224 – Other alloy steel in ingots or other primary forms; semi- finished products of other alloy steel
Iron or steel products
7205 – Granules and powders, of pig iron, spiegeleisen, iron or steel (if not covered under category pig iron)
7208 – Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, hot-rolled, not clad, plated or coated
7209 – Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, cold-rolled (cold-reduced), not clad, plated or coated
7210 – Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, clad, plated or coated
7211 – Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, not clad, plated or coated
7212 – Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, clad, plated or coated
7213 – Bars and rods, hot-rolled, in irregularly wound coils, of iron or non-alloy steel
7214 – Other bars and rods of iron or non-alloy steel, not further worked than forged, hot-rolled, hot-drawn or hot-extruded, but including those twisted after rolling
7215 – Other bars and rods of iron or non-alloy steel
7216 – Angles, shapes and sections of iron or non-alloy steel
7217 – Wire of iron or non-alloy steel
7219 – Flat-rolled products of stainless steel, of a width of 600 mm or more
7220 – Flat-rolled products of stainless steel, of a width of less than 600 mm
7221 – Bars and rods, hot-rolled, in irregularly wound coils, of stainless steel
7222 – Other bars and rods of stainless steel; angles, shapes and sections of stainless steel
7223 – Wire of stainless steel
7225 – Flat-rolled products of other alloy steel, of a width of 600 mm or more
7226 – Flat-rolled products of other alloy steel, of a width of less than 600 mm
7227 – Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel
7228 – Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel
7229 – Wire of other alloy steel
7301 – Sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel
7302 – Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish- plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialised for jointing or fixing rails
7303 – Tubes, pipes and hollow profiles, of cast iron
7304 – Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel
7305 – Other tubes and pipes (for example, welded, riveted or similarly closed), having circular cross-sections, the external diameter of which exceeds 406,4 mm, of iron or steel
7306 – Other tubes, pipes and hollow profiles (for example, open seam or welded, riveted or similarly closed), of iron or steel
7307 – Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel
7308 – Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge- sections, lock- gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns), of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel
7309 – Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 l, whether or not lined or heat- insulated, but not fitted with mechanical or thermal equipment
7310 – Tanks, casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
7311 – Containers for compressed or liquefied gas, of iron or steel
7318 – Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel
7326 – Other articles of iron or steel
Nitric acid
2808 00 00 – Nitric acid; sulphonitric acids
Urea
3102 10 – Urea, whether or not in aqueous solution
Ammonia
2814 – Ammonia, anhydrous or in aqueous solution
Mixed fertilizers
2834 21 00 – Nitrates of potassium
3102 – Mineral or chemical fertilisers, nitrogenous except 3102 10 (Urea)
3105 – Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus, and potassium; other fertilisers – Except: 3105 60 00 – Mineral or chemical fertilisers containing the two fertilising elements phosphorus and potassium
Hydrogen
2804 10 00 – Hydrogen
Electricity
2716 00 00 – Electrical energy
Where fewer than 8 digits appear, it means that all CN codes starting with those digits are covered.
Check out the number of CN Goods per “aggregated goods category”
A "CN good" refers to a product or item that is classified according to the Combined Nomenclature (CN). The CN code is an 8-digit classification system used within the European Union (EU) for the declaration of goods at customs and for statistical purposes. It builds upon the international Harmonized System (HS), which is a standardized 6-digit code used worldwide to identify products. The first 6 digits of the CN code are the HS subheading, providing a broader classification of the goods. The CN adds two extra digits to this HS subheading, creating a more detailed classification to meet specific EU requirements for customs, taxation, and trade statistics.
Under the EU's CBAM framework, each CN code is grouped into what is termed an "aggregated goods category". This grouping comprises various CBAM goods, which, despite having different CN codes, share similar characteristics that allow for the application of common monitoring rules. These categories are created to simplify the administration and implementation of CBAM. Your suppliers will use them to monitor and calculate their emissions, so it's helpful for you to become familiar with how they link to each CN good. In total, the EU CBAM currently encompasses 20 different aggregated goods categories.
2. Start engaging with your suppliers
It’s time to have a CBAM conversation with your suppliers. First, identify which suppliers you are purchasing your CBAM goods from and contact them as soon as possible. They need to start compiling some data for you to meet your CBAM reporting requirements. To simplify the communication of this data, the European Commission has made a CBAM communication template available on its dedicated CBAM website.
But don’t worry, if your suppliers don’t provide you with all the emissions data that you need for the first CBAM quarterly report, you’ll be able to use a list of default values published by the EU Commission. This flexibility will apply for the first three CBAM reports.
I hope this message finds you well. As the designated point of contact for [Full Company Name], I am reaching out in relation to the new EU Carbon Border Adjustment Mechanism (CBAM) reporting obligations our company is subject to.”
What type of data do you need to gather?
Data about your suppliers and the installations where they produce the CBAM goods.
In the CBAM context, "suppliers" refers to the operators of the installations.
Data about the specific direct and indirect embedded emissions of your imported CBAM goods, expressed as tCO2 per tonne of good.
This information is needed to be able to calculate the embedded emissions of your imported CN goods, which involves multiplying the imported quantity of a given CN good by its specific embedded emissions.
On the one hand, the production method or production route refers to the specific technology used to produce the CBAM goods. For instance, if your supplier produces hydrogen, different production methods can be used such as steam methane reforming (SMR) or partial oxidation.
On the other hand, the additional qualifying parameters refer to quality information of the imported CBAM goods. For example, if you import cement, the total clinker content needs to be reported.
These qualifying parameters depend on the goods produced and are listed in section 2 of Annex IV of the EU CBAM Implementing Regulation.
If your supplier (the operator) has already paid a carbon price in the country of origin for part or all of the emissions from the installation it operates, this information should be included in the CBAM report. The same requirement applies to any precursors purchased for which a carbon price has been paid in its country of origin.
Why is this important? Including any carbon prices paid in the country of origin will enable you, as the EU importer, to reduce your CBAM payment.
Relevant precursors in the CBAM context are CBAM goods with embedded emissions that are used as inputs to produce other CBAM goods. When calculating the total embedded emissions of a CBAM good, emissions from any relevant precursors must be added.
The CBAM goods with relevant precursors are referred to as "complex goods". These complex goods can also be relevant precursors themselves. On the other hand, "simple goods" refer to goods without relevant precursors, meaning they are produced in a process that exclusively requires input materials and fuels that under the EU CBAM are deemed to have zero embedded emissions.
For instance, cement clinker (a simple CBAM good) is a precursor to cement, a complex CBAM good. Moreover, a steel rod, classified as a complex CBAM good, can also serve as a relevant precursor to other complex CBAM goods, such as screws and nuts. Similarly, a mixed fertilizer may be used as a precursor in the production of another mixed fertilizer.
While precursor data does not need separate reporting in the CBAM report, obtaining this information from suppliers can facilitate the checking of the reported data.
3. Get ready for reporting
To submit your EU CBAM report, you must first request access to the EU CBAM Transitional Registry from your National Competent Authority (NCA). The EU Commission has listed the NCAs on its CBAM-dedicated website. After gaining access to the EU CBAM Transitional Registry, you can upload your EU CBAM Report in XML format or manually input the data.
Our platform will enable you to generate XML reports effortlessly, allowing you to focus on decision-making. For the initial CBAM report, we will work closely with your team to assist in understanding, collecting, and submitting all necessary parameters to the EU Commission via the CBAM Transitional Registry.
Find out more about our product and its CBAM-related features on our product page.
Report Structure
Customs Information
In the CBAM report, the imported quantity of each CN good has to be reported per customs procedure. The table below provides a description of the relevant customs procedures.
4. Submit your CBAM Report
After inputting your data or uploading the XML file to the CBAM Transitional Registry, you need to ensure you submit it to the Commission by the end of January 2024. For the first reporting period, which spans October to December 2023, the reporting window will open on January 1, 2024. Keep in mind that for determining the date a CBAM good was imported, and hence to which CBAM report it belongs, the “release to the market” (i.e., the clearance by the customs authority) is what matters.
You will have the opportunity to modify your initial CBAM report even after submission, as the EU CBAM Implementing Regulation provides an extended correction period for the first two quarterly reports. For instance, this will allow you to correct previously submitted reports with more accurate data on embedded emissions.
Penalty Simulator
Penalties may be imposed where reporting declarants fail to take the necessary steps to comply with the obligation to submit a CBAM report or where a competent authority initiates a correction procedure and the reporting declarant does not take the necessary steps to correct the CBAM report.
The amount of the penalty will be between EUR 10 and EUR 50 per tonne of unreported emissions and will increase in accordance with the European index of consumer prices. The calculation of the penalty will be based on the default values made available by the Commission for the transitional period.
*The actual amount of a penalty will be determined by the relevant competent authority after considering a set of factors listed in Article 16.3 of the CBAM Implementing Regulation.
Penalty Simulator
Penalties may be imposed where reporting declarants fail to take the necessary steps to comply with the obligation to submit a CBAM report or where a competent authority initiates a correction procedure and the reporting declarant does not take the necessary steps to correct the CBAM report.
The amount of the penalty will be between EUR 10 and EUR 50 per tonne of unreported emissions and will increase in accordance with the European index of consumer prices. The calculation of the penalty will be based on the default values made available by the Commission for the transitional period.
Relevant dates to keep in mind for 2024
Can I use only default values for this report?
Yes, you'll be able to use default values to calculate the embedded emissions of your imported CN goods.
Will I be able to modify this report?
Yes, you will have until the submission of the third CBAM report (July 31, 2024) to amend the content of the first and second CBAM reports.
Can I use only default values for this report?
Yes.
Deadline to modify this report
July 31, 2024
Can I use only default values for this report?
Yes.
Deadline to modify this report
August 30, 2024
Can I use only default values for this report?
No. For this report, there is a quantitative limit on the use of default values. Specifically, up to 20% of the total embedded emissions of complex goods may be calculated using default values or other estimations.
Deadline to modify this report
November 30, 2024
Are there other flexibility measures for this report?
Yes. Until 31 December 2024, your suppliers (i.e., the third-country operators) can use alternative monitoring and reporting methods already in place at their installations if:
- The installation is covered by a carbon pricing scheme.
- The installation is covered by a compulsory emissions monitoring scheme.
- The installation is subject to a monitoring scheme that includes verification by an accredited verifier.
Go to our Overview page for the comprehensive CBAM timeline.
5. Start managing your CBAM-related costs
Try out our free CBAM calculator
Emission Factors
CBAM Obligation
CBAM Adjustment
*This calculation assumes that 100% of the embedded emissions are covered by the carbon pricing regime in origin and that no rebate or compensation mechanisms apply. Please note that this is a basic calculator provided for illustration purposes. To gain full control over your CBAM-related costs, book a demo of our Carbon Pricing Platform.
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