Reports on the emission data of imports

Under the new CO2 border adjustment mechanism, companies must quarterly on the emissions embodied in their affected imports. emissions embodied in their affected imports. The regulation provides various options available.

The default values

Until the CBAM report, which is now due in July, companies may report using report with default values provided by the European Commission. provided by the European Commission. They are divided into direct and indirect emissions and refer to the number of the Combined Nomenclature. Nomenclature. With these default values, which show the emissions per unit of the imported product, companies can easily compare the emissions report on emissions using the import data available to them. report. Companies subject to CBAM are even complaining about why this task falls to them. After all, the customs authorities would also have access to all import data and could also use the standard determine the emissions themselves and automatically using the standard values.

Emission monitoring systems

In addition, affected companies will still be able to access data until December 31 data that their producer in the third country has collected using other has collected using other monitoring or reporting methods. This includes CO2 pricing systems, mandatory emissions emission monitoring systems or an emission monitoring system that which may also include verification by an accredited verifier.

With this producer-related deviation, however, it should be noted that such systems must lead to a similar coverage and accuracy accuracy as the complex CBAM monitoring methodology does. does. It is therefore by no means the case that it is possible to to simply report any emissions data, as is sometimes is sometimes heard. If this methodology is chosen, the alternative method must also be named in the CBAM report.

Actual emission data

Unless an alternative emissions monitoring system cannot be used, actual emissions data must already be used for the CBAM report due in October. This is likely to be the case for the vast majority of companies subject to CBAM.

The companies concerned must therefore obtain and report actual emissions data from data from their supply chain and report it. This poses major challenges, especially major challenges in the case of complex goods. Complex goods are defined as are defined as imports that were manufactured from goods whose production production of which emissions have already been released.

Manufacturers of complex goods must therefore also take the emissions of these relevant precursor products. This means that they must emissions from their suppliers if they do not use the precursor product precursor product in their own plant. The The complexity of the emissions calculation therefore increases with the complexity of the supply chain. This is because, here too, the emissions of the precursor products must be calculated using the corresponding CBAM methodology. must be calculated.

The regulation aims to remedy this situation by allowing complex goods, even beyond July, to a limited extent by using standard to use standard values for the calculation. Up to 20% of the of the total emissions of a complex product may be calculated CBAM transition phase with standard values.

The fact that this only helps to a limited extent is quickly demonstrated by the example of fasteners. Here, the majority of the emissions are attributable to the precursor product. If the emission values cannot be obtained from the cannot be obtained from the upstream supplier, the exemption is of little help.

Obtaining emission data

If you have difficulties obtaining the actual emission data, please data, please contact me directly (helge@kolum.earth). Your manufacturers can be guided step by step in our software your emissions in a CBAM-compliant manner and then share them with you. then share them with you.

Best regards

Helge Wieggrefe