The CBAM Self Assessment Tool of the European Commission

The European Commission has published a new tool this week, the so-called CBAM Self Assessment Tool. This is intended to simplify the handling of CBAM for companies. The new tool will therefore be presented and explained in more detail.

General information

The XLSX file is available on the website of the European Commission under this link. The aim of the file is to give the companies concerned a quick overview of whether a consignment of goods falls under the regulation. If this is the case, the file also provides an overview of the required data points.

Structure of the file

The file is divided into two main sections. On the one hand, it contains an initial yellow section in which the user can and must make entries. The entries are then checked and the results are displayed in a subsequent green area. The yellow section also contains helpful descriptions of the required data points. This should be particularly helpful for small companies that do not have the capacity or resources to familiarize themselves with the details of the regulation, or companies that do not employ experts in the field of customs law.

Impact analysis

The file carries out the impact analysis based on the Combined Nomenclature number of the goods in question, the origin of the goods, the value of the CBAM goods in the consignment and the so-called purpose of the import. This translates the technical exceptions of the regulation into a more accessible language. Together with the attached definition, this is to be welcomed. It would be nice here, as well as in general, if the file were available not only in English but also in other languages. After all, a translation would make it much easier to familiarize oneself with such a complex topic. Especially if the self-assessment tool is intended as an introductory aid for the companies concerned, this would be a sensible measure. However, experience with the EU's other guidance documents gives us hope that the European Commission will quickly make improvements here.

Required data

If the yellow part of the file is used accordingly, the green part initially provides information on whether the consignment of goods under investigation falls under the regulation. It also provides an overview of the data points required for the consignment of goods, which the company should request from the supplier or manufacturer. This section begins with the “Quantity of goods”, described as “Quantity of goods imported expressed in tons”. This is an important data point for the CBAM report. However, it is not clear why the quantity of goods imported should be requested from the supplier. The European company should be able to provide information on this itself by using the information from the customs declaration or customs notification. The other data includes the country of origin of the goods, information on the installation, direct emissions, the production method, other qualifying parameters that affect emissions, indirect emissions, information on data quality and any CO2 price already paid. It would have been desirable if the European Commission had identified the really necessary data points here and brought them into line with the report structure file. Especially if the tool is intended to support companies that have not yet been affected by CBAM at all or not to any great extent, it would have been easy to provide even more support here. Assessment In conclusion, it can be said that any further assistance from the European Commission is generally to be welcomed. The self-assessment tool certainly comes a little late and would have been even more effective in October last year, when all companies carried out the impact analyses for the first time. Nevertheless, in view of the fact that the scope of application of the regulation is likely to expand, it can also offer support to newly affected companies in the future. It can also be a useful aid for smaller companies that are still struggling with this due to a lack of capacity. However, the file certainly has even more potential than is currently being exploited. But it is also called version 1.00. Above all, it is to be hoped that it will also be translated into other languages to create more clarity for the data points.

Support in the impact analysis

If you need support with the impact analysis or have any other problems implementing the requirements in your company, please contact us directly (helge@kolum.earth). We will be happy to help you.

Best regards Helge Wieggrefe