CBAM: Reporting - Responsibilities & Procedures

As the Carbon Border Adjustment Mechanism (CBAM) rolls out, understanding the roles and responsibilities associated with reporting is crucial for compliance. Here's a comprehensive overview of the procedures, authorities, and reporting obligations under CBAM.

The European Commission's Role

During the transitional period of CBAM, the European Commission plays a multifaceted role. It manages the CBAM Transitional Registry, reviews reports from declarants, and communicates any potential non-compliance issues to national competent authorities (NCAs). The Commission also monitors the implementation and impact of CBAM, analyzing its effects on exports, trade flows, and least developed countries (LDCs). Additionally, the Commission is tasked with preparing secondary legislation through implementing and delegated acts to refine reporting obligations, verification processes, and carbon pricing.

National Competent Authorities (NCAs)

Each EU Member State has designated an NCA responsible for ensuring compliance with CBAM rules. NCAs check the quality of CBAM reports and engage with reporting declarants to address any issues. They have the authority to impose penalties for non-compliance. From 2025, NCAs will also grant ‘authorised CBAM declarant’ status.

Importer Authorization and Verification

Importers do not require authorization to import CBAM goods during the transitional period. However, verification by an external body is not mandatory until 2026, with secondary legislation setting out the verification rules based on data collected during the transitional period.

Reporting Emissions

Different CBAM sectors have specific reporting requirements. For instance, cement and iron/steel sectors need to report both direct and indirect emissions, while sectors like aluminium and hydrogen only report direct emissions. The methods for calculating embedded emissions vary by sector, and default values can be used for estimates until mid-2024.

Issue	CBAM good
	Cement	Fertilisers	Iron/Steel	Electricity	Aluminium	Electricity
Reporting metrics	(per) Tonne of good
Greenhouse gases covered	Only CO2	CO2 (plus nitrous oxide for some fertiliser goods)	Only CO2	Only CO2	CO2 (plus perfluorocar bons (PFCs) for some aluminium goods)	Only CO2
Emission coverage during transitional period	Direct and indirect
Emission coverage during definitive period	Direct and indirect	Only direct, subject to review

Information from Producers

To ensure accurate quarterly CBAM reports, declarants must obtain information from producers in third countries as specified in the relevant regulations. The Commission provides a communication template to facilitate this exchange of information.

Document Submission and Reporting

Declarants need not submit original documents with their quarterly CBAM reports. Instead, they should provide required information through the CBAM Transitional Registry and maintain transparent records of data for at least four years.

Filing Reports

If a declarant acts both as an importer and an indirect customs representative, they should file a single CBAM report that consolidates all relevant goods. The effective carbon price, which reflects the monetary amount paid in a third country for emission reductions, must be reported, especially during the transitional period.

Accuracy and Corrections

The Commission will initially review CBAM reports and identify any issues for further review by NCAs. Declarants can correct their reports within two months after the reporting quarter, with extended correction deadlines for the first two reports.

Language and Reporting Flexibility

Reports can be submitted in any of the 24 EU languages, providing flexibility for declarants across different Member States. Understanding and adhering to these guidelines will ensure compliance with CBAM reporting obligations and contribute to the mechanism's effectiveness in addressing carbon emissions.