CBAM – Carbon Border Adjustment Mechanism

What is CBAM?

The Carbon Border Adjustment Mechanism (CBAM) mandates that EU-based businesses importing iron, steel, fertilisers, electricity, aluminium, cement, and hydrogen report and offset the carbon dioxide emissions linked to these imports from outside the EU. 

We are currently in the transitional period of CBAM, which began in October 2023. During this phase, businesses must start requesting and using real emissions data by the third quarter of 2024. The requirement to compensate for emissions, involving the purchase of CBAM certificates, is set to commence in January 2026. 

For businesses, CBAM incurs two types of costs: 

  1. CBAM certificates, priced according to the EU Emissions Trading System (ETS)
  2. Significant administrative costs associated with collecting and reporting emissions-related data. 

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The transition to CBAM

For each product type listed in the scope of CBAM, dependent on the commodity code, importers must submit quarterly reports detailing both direct and indirect emissions during the transition period. 

The transitional period does not yet incur expenses associated with the purchase of certificates, since reporting does not yet require CBAM certificates to be surrendered. However, reporting is mandatory despite this.  

It should be underlined that the implementation of reporting procedures during the reporting phase makes it possible to anticipate future costs associated with emissions in contracts, resale pricing, and supplier selection. 

CBAM timeline

How can we help

Product identification & Establishment of import profile

Based on the import data provided by the customer, the Customs authority, Brokers, or ERP for the CBAM reporting period, we analyse the company's imports and create supplier-specific summaries for "CBAM suppliers." At this stage, based on our import analysis, we can also provide recommendations for the reclassification of products under different tariff headings, potentially placing them outside the scope of CBAM. With our extensive experience in product classification, we can develop and implement procedures that simplify the classification of both new and existing products. 

Data collection & Supplier communication

Goin forward from Q3/2024, real emissions data must be gathered. To assist with the data gathering process, which is probably the most challenging aspect of CBAM, our services also include providing a simplified data-gathering Excel template, which is more user-friendly compared to the version provided by the EU Commission. Additionally, to facilitate communication with third-country suppliers, we supply a communication template in the form of an email draft. This draft can be sent alongside the Excel template to inform suppliers about the necessary actions they need to take.

Emissions calculations & Due diligence

If the supplier communicates emissions data and provides the required data using our Excel template or other acceptable formats, we calculate the direct and indirect emissions based on the methods outlined in the Annexes of the legislation. This process also includes verifying the reported emissions variables. We maintain ongoing communication with suppliers to ensure consistent production methods and valid calculation bases between reporting periods, thus maintaining data validity and ensuring CBAM compliance. 

In cases where the supplier does not provide emissions data, we use the "default" emission values published by the Commission to enrich the CBAM import data, ensuring a form of CBAM compliance despite the lack of direct data. We report non-compliant suppliers and provides necessary documentation for the Commission, serving as a record of compliance efforts. Additionally, we can assist in developing a due diligence procedure to evidence reporting efforts, demonstrating the company's commitment to compliance and helping to mitigate risks from non-compliant suppliers. 

Finalisation of the CBAM report

Once we have calculated the emissions based on the data from suppliers, we convert the completed CBAM report into the XML format required by the Commission's Trade Registry. This process ensures that all data is accurately represented and formatted according to the Commission's specifications, facilitating a smooth and error-free submission. 

Additionally, we assist you with the upload and submission of the XML file to the CBAM portal. Our team provides guidance and support throughout the registration and submission process, ensuring your organisation meets all deadlines and compliance requirements. 

By handling the conversion and assisting with submission, we streamline the reporting procedure, significantly reducing your administrative burden and ensuring efficient compliance. In other words, our CBAM experts and our comprehensive CBAM service not only ensures compliance but also reduces the administrative resources needed by outsourcing the process to us. 

The full implementation of CBAM

When CBAM is fully implemented, its product scope is expected to expand. Importers will need to compensate for emissions associated with imported goods by purchasing and submitting CBAM certificates. These certificates will be priced based on a weekly average auction price of EU ETS allowances, expressed in €/tonne of CO2 emitted. 

In preparation for the definitive period, we are continuously developing our tool to accommodate the requirements of the definitive period, making it easier for your company to evaluate the number of certificates needed, manage their purchasing, generate emission reports, and facilitate the handover of certificates.

Why should you choose PwC as your partner for CBAM obligations?

Our strength is cooperation between different teams. Our customs and tax technology teams support you in the automation of the CBAM obligations. In addition, if necessary, we offer legal services for drafting contractual obligations and logistics experts that can assist with eventual changes in your supply chains. Furthermore, we collaborate closely with our regional offices from around the world, which enables quick and effortless support in the collection of information from suppliers if necessary.

Tutorial video for our clients

How to submit the CBAM report to the registery

In case of any issues, please contact our experts.

 

Ota yhteyttä

Aku Korhonen

Aku Korhonen

Partner, Tax and Legal Services, PwC Finland

puh. +358 (0)20 787 7229

Arthur Österholm

Arthur Österholm

Customs, Excise & International Trade, PwC Finland

puh. +358 20 787 8344

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