The first reporting period with real emissions data

On October 1, the first CBAM reporting period began in which actual emissions data must be used. Importers are now required to provide the relevant data for goods imported in the third quarter of this year. The most important points for reporting in October are therefore summarized below.

No verification requirement

Unlike in the regular phase from 2026, the reported emissions data does not yet have to be verified by an accredited verifier. Nevertheless, companies should carry out a plausibility check of the data they have received from the manufacturer in the third country. In some cases, difficulties arise here if no in-depth familiarization with the manufacturing processes of the goods and the emission monitoring methodology of the regulation has yet taken place.

Renewed update of the reporting structure

On October 1, the European Commission published a further update to the reporting structure. For affected companies, this is of course quite short notice with regard to the reporting period that has just begun. This is all the more true as extensive changes have been introduced. A total of 30 adjustments have been made.

Missing emissions data?

If companies still do not have all the actual emissions data, you must provide detailed information in the CBAM report on what you have done to obtain the data. It is important to really explain all your efforts. This is because these will significantly influence the decision of the national competent authority as to whether it will exceptionally refrain from imposing sanctions. An explanation should also be provided as to why the process ultimately failed. Was there any feedback from the manufacturer? Did he finally refuse? You must also provide evidence of the efforts made and submit them to the right place with your CBAM report. You can now upload documents to the CBAM Transitional Registry for this purpose.

Modifying period

Each CBAM reporting period is followed by a correction period. Companies therefore have the option of modifying and supplementing the submitted CBAM report as required. Previously, this was easier for companies, which were allowed to amend the first due reports until the end of July. Now this option is only available in the following month. Companies can still make use of this until the end of November for the Q3 report.

Continue to make efforts

This also means that companies should continue to intensify their efforts to obtain the data. If emissions data can still be obtained in November, you can submit it in full and avoid penalties accordingly. Of course, this also applies to the upcoming reporting periods.

Support for the Q3 report

If you have any difficulties in obtaining the emissions data or managing the evidence of your efforts, please contact us at any time (helge@kolum.earth) We will be happy to support you in your CBAM compliance process! Best regards Helge Wieggrefe