The CBAM transition phase in a nutshell

As part of the Green Deal, the European Commission has introduced the Carbon Border Adjustment Mechanism (CBAM), the world's first CO~2~ border adjustment mechanism. This is a a second emissions trading system for imports into the European Union. It is intended to prevent greenhouse gas emissions from being shifted to countries with less stringent climate protection requirements than the European Union and at the same time reduce global emissions.

Scope of application

CBAM came into force in October 2023 with a transitional phase and initially applies to certain goods from the iron and steel sectors, aluminium, cement, fertilizers, electricity and hydrogen. The analysis must be carried out on the basis of the customs tariff number. number. An extension of the catalog of individual goods as well as the sectors sectors affected is already laid down in the European regulation. is already laid down in the European Regulation.

Requirements for affected companies

Until the end of 2025, importers in the transition phase are are obliged to report quarterly on the emissions associated with the imported emissions associated with the imported affected goods. They can do this in the phase until July 31, 2024, they will still be able to use standard values values provided by the European Commission until July 31, 2024. provided by the European Commission. They can also amend the first two CBAM reports that are due subsequently until this date. The biggest hurdles hurdles for companies were therefore initially to familiarize themselves with the new the new regulation, organizing the internal customs data, gaining access to the access to the EU portal and familiarizing themselves with the reporting format. reporting format. For larger companies (groups) in particular, reporting can can cause considerable effort.

For the report due in October 2024, actual emissions data must then be actual emissions data must be reported for the first time. Obtaining the emission data poses major challenges for companies, particularly in the case of complex downstream goods in particular.

Sanctions

Compliance with the requirements is monitored by the German Emissions Trading Authority (DEHSt). There is already a threat of sanctions of 10 to 50 euros per tonne of unreported emissions if the company concerned company concerned fails to take the necessary measures to fulfill the to fulfill the obligation to submit a CBAM report or the CBAM report is or the CBAM report is incomplete or inaccurate and the company does not correct it even after being requested to do so by the DEHSt. corrected.

In addition, penalties of more than 50 euros per tonne of of unreported emissions if incomplete or incorrect reports are submitted more than twice in a row. incomplete or inaccurate reports have been submitted more than twice in a row or the reports have not been submitted for more than six months.

Before sanctions are imposed, a correction procedure is always carried out. rectification procedure is always carried out. However, the companies concerned affected companies cannot rest on their laurels if they are unable to correct the CBAM reports reports because they do not have the correct emissions data.

Support

If you have problems implementing the CBAM requirements in your company company or are facing challenges in obtaining the actual emissions data actual emissions data, please feel free to send me a short mail to helge@kolum.earth. We will will be happy to support you and make your company CBAM-ready.

Best regards

Helge Wieggrefe