CBAM: From standard values to detailed emission data 

Starting July 1, 2024, companies importing goods into the EU must comply with enhanced reporting obligations under the Carbon Border Adjustment Mechanism (CBAM). These obligations are particularly relevant for companies that import highly CO2 embedded goods such as steel/iron, aluminium, hydrogen, cement, fertilizers, and electricity. Until that date, companies may report embedded emissions in imported goods using default values provided by the European Commission. However, from 1 July 2024, these default values can only be used to a limited extent, specifically for up to 20% of the total specific embedded emissions of complex goods. This means that from this date, companies must provide more precise and detailed emission data for the majority of their reporting. 

Challenges in obtaining actual emissions data

Going forward, importers will need to obtain specific emissions data from their suppliers. In many cases, such data is not readily available because suppliers are not yet familiar with CBAM and the obligation to collect such emissions data, or because suppliers are not yet capable of monitoring and collecting the required emissions data. 

What are the implications of missing emissions data? 

The Dutch Emissions Authority (NEa), which, together with the European Commission, is responsible for enforcing the CBAM in the Netherlands, recognizes the challenges in obtaining relevant emissions data from foreign suppliers. Nevertheless, the NEa expects each importer to undertake all reasonable efforts to obtain the relevant emission data from foreign suppliers. What constitutes reasonable efforts varies per importer. More effort is expected from importers who import large quantities of CBAM goods covering higher CO2 emissions than from importers who import smaller quantities of CBAM goods with lower emissions. 

Past CBAM deadlines 

• 31 January 2024: Due date of first CBAM reporting covering the period October – December 2023. 

• 30 April 2024: Due date of second CBAM reporting covering the period January – March 2024. 

Upcoming CBAM deadlines

• 1 July 2024: Start of increased reporting obligations based on actual emissions data and limited use of default values. 

• 31 July 2024: Due date of third CBAM reporting covering the period April – June 2024. Companies can adjust and correct their first three CBAM reports until 31 July 2024.  

• 1 January 2026: From this date, the full CBAM mechanism comes into effect, and importers must purchase and submit CBAM certificates for the embedded CO2 emissions in their imported goods. 

Does your organization import steel/iron, aluminium, hydrogen, cement, fertilizers, and electricity? If so, it is essential to start collecting the required data in a timely manner to remain compliant and avoid fines. Even if the required emissions data is not immediately available, importers are required and recommended to still submit a CBAM report and continue discussions with their suppliers to be well-prepared for future reporting and to avoid any potential penalties. 

Need help with CBAM reporting and this transition from standard values to actual emissions data? 

Our team of CBAM specialists is ready to assist you. We ensure that you remain compliant, minimize the risk of fines, and facilitate discussions with your suppliers. Fill out the contact form and we will get in touch within one business day.