The methodology of emission monitoring for CBAM

The CBAM Implementing Regulation allows the unlimited use of default values only until July 31, 2024. only until July 31, 2024, which marks the end of the last reporting reporting period in which the emission values of the imported goods were goods can be determined in this simplified manner.

Period of validity

When the regulation refers to the date at the end of July, it is referring to the CBAM reports and not to the imported goods. This means that the CBAM report for the third quarter of 2024 must be prepared with the actual emission values must be prepared. This does not mean means that the stricter rules will only apply to imports from August 1, 2024 rules apply and that importers for goods imported in July may still use the standard values. For all imports in the third quarter, actual emissions data must be obtained and reported. be reported.

CBAM calculation method

The calculation of emissions data must be carried out by the installation operator in the third country. He must monitor the emissions for each production plant. for each production facility. The Implementing Regulation follows the so-called “top-down” approach. This means that the installation operator must first determine emissions at installation level. The total emissions of the plant are then broken down into the individual production broken down to the individual production processes. This approach approach is due to the fact that the European Commission rightly Commission rightly assumes that the production facilities in question no measuring instruments for the individual production processes are are present in the production plants concerned. However, in the absence of such instruments, the other “bottom-up” approach is hardly feasible. This is because the emissions of the individual relevant production processes cannot be determined in order to allocate them to the goods produced.

Background to the methodology

The European Union mirrors the emissions monitoring rules for the European Emissions Trading System to the non-European third country. Since emissions trading system, unlike CBAM, is plant-related and not product-related product-related, this is not possible without further ado. Instead, the emissions monitoring methodology was adapted accordingly and transferred to products. The result is that the emission monitoring rules for the Carbon Border Adjustment Mechanism follow their own approach and also set their own standard for emissions monitoring of goods.

Difference to other Product Carbon Footprints

There are therefore corresponding differences in the so-called system boundaries of emissions monitoring for CBAM compared to the established Product Carbon Footprint_ standards. The system boundaries define which input materials, intermediate products and corresponding emissions must be monitored.

In general, for CBAM, the production of precursor products and the production of the CBAM-relevant goods themselves must be monitored. A complete Product Carbon Footprint also includes the upstream upstream raw material production and downstream the utilization phase of the use phase of the goods, including distribution, as well as the end of the usability of the goods and thus the reuse, recycling or waste disposal. waste disposal.

Support

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Best regards

Helge Wieggrefe