Background to the update of the CBAM report

During the transition phase of the Carbon Border Adjustment Mechanism, affected economic operators are obliged to submit a CBAM report on a quarterly basis. The report can be prepared and submitted directly in the CBAM Transitional Registry of the European Commission. However, it can also be prepared externally and then uploaded there. The European Commission published an update on the XML structure this week.

Structure of the CBAM report

The CBAM report is divided into various sections. It begins with the so-called “header” section, which primarily contains general information on the economic operator subject to reporting as well as administrative information on the reporting period and the competent authority. This is followed by (customs-related) information on the imported goods, their manufacturers and the emissions embodied in the goods.

The report structure file

The report structure file supports companies if they decide to prepare the report outside the CBAM Transitional Registry. You can find the file here. It also shows that a CBAM report can consist of up to 272 different elements in the XML structure. If there are several imports from different manufacturers from different countries, the number of data fields in the file increases accordingly.

Working with the file

The report structure file also shows which data fields are optional and which are mandatory for creating a report. It even provides information about the multiple rules that apply. For example, a data field may become mandatory if you omit another one or, conversely, a data field may be required because you have selected and filled another one.

Changes to the XML structure

An overview of the Commission's changes for the coming reporting period can be found here. The main changes affect the report structure file and the sample XML files that are provided as support, but also the manual for using the CBAM transition register.

Administrative data fields in the “Header” area such as “Report issue date”, “Draft report ID” and “Date of signature” have been deleted. The fields “Total goods imported” and “Total emissions” no longer need to be filled in either. These have aggregated data from the following information in the report.

Furthermore, the fields “Goods imported total emissions” and “Installation emissions” are also omitted. This also includes the corresponding information for these two fields.

There are also changes to the information on a CO2 price incurred in a third country, which is probably rarely used. In future, the “Exchange Rate” and the “Amount (EURO)” no longer have to be stated here.

Background to the changes

The European Commission has not published any precise details on the reasons for the changes. Ultimately, the reduction in administrative information is likely to simplify the process. The CBAM Transitional Registry can also generate this information itself, for example.

Rounding errors in the calculation value space

In the case of the information on the total emissions of the imported goods and those of the production site, it is likely to have been a matter of correcting an error with regard to the reporting of actual emission values and the limit of permissible decimal places.

This is because the accuracy of the determined emission values previously suffered from the limitation of the transferable values in the specified XML structure.

For example, 6 decimal places were permitted for 'NetMass', 7 decimal places for 'EmissionsPerUnit' and also 7 decimal places for 'OverallEmissions'.

The 'OverallEmissions' resulted from the multiplication of the 'NetMass' with the 'EmissionsPerUnit'. This resulted in a possible calculation value space with 13 decimal places for the 'OverallEmissions'.

We have found that although our customers can provide very accurate values in both their 'NetMass' and 'EmissionsPerUnit', they have not been able to report this accuracy due to the limitation.

Support in the reporting process

If you find the manual reporting process in the portal too time-consuming or have difficulties identifying the required data points, please contact us (helge@kolum.earth). We will accompany your process from the first (emission) data query to the automated submission in the CBAM Transitional Registry.

Best regards

Helge Wieggrefe