The EU has published a comprehensive Q&A on the CBAM

The EU published a Q&A text regarding the Carbon Border Adjustment Mechanism (CBAM) on 28 November 2023


The European Commission published a Q&A text containing the current situation regarding the Border Carbon Regulation Mechanism (CBAM) on 28 November 2023.

You can access the original document of the Q&A text by clicking here

Question and Answer text content;

Question and Answer Text mainly focuses on the transition phase of the Border Carbon Adjustment Mechanism (CBAM), which came into force on October 1, 2023, and the SKDM, which will continue until January 2026. Some questions regarding the final period (starting in January 2026) are also addressed.

In the text, the basic principles and application processes of SKDM are discussed in detail. In addition to general information about SDDM, reporting processes, carbon emissions calculation methodologies, sectoral-based application details and information about the final phase that will start after January 1, 2026 are presented.

The text includes information about the reasons for implementing the CBAM application, its scope, reporting processes and responsibilities.

Question Titles:

· Why is the EU introducing a Carbon Border Adjustment Mechanism?

· What is the current stage in the implementation of CBAM?

· How does CBAM work?

· How does CBAM interact with the EU Emissions Trading System (ETS)?

· In what ways is CBAM compatible with other ETS systems outside the EU?

· Which sectors do the new mechanism cover and why were these sectors chosen?

· For which goods does the CBAM Regulation apply?

· Does CBAM apply to 'second-hand' goods?

· Does CBAM apply to 'returned goods'?

· How will CBAM combat carbon leakage of finished or semi-finished products?

· Which third countries are covered by CBAM?

· Do I need to report imports of CBAM products originating from the UK?

· What happens during the transition period?

· Are there any penalties for non-compliance with the CBAM Regulation?

· Where can I find detailed information on how to report embodied emissions?

· Is it mandatory to use the communication template Excel file?

· Who is responsible in case of incorrect or insufficient information?

· Who can I contact if I have more and more specific questions?

· Reporting: general topics

· Who is responsible for reporting?

· Can an importer have more than one indirect customs representative?

· Will companies be allowed to report at central level if subsidiaries in different Member States have different Economic Operators Registration and Identification (EORI) numbers?

· What are the reporting obligations? By when do I have to submit a report? Reporting Schedule, Content of the report

· I import CBAM products in very small quantities. Do these products fall within the scope of the CBAM Regulation?

· Reporting: responsibilities and procedures

· What is the role of the European Commission in the transition period?

· What is the national competent authority (NCA)?

· Do importers of CBAM products need to be 'authorised' to import CBAM products during the transition period?

· Are there verification obligations during the transition period?

· What embedded emissions must be reported by each CBAM sector?

· What information should reporting declarants request from producers in third countries to enable them to submit the quarterly CBAM report?

· What documents must be originally provided to verify CO2 emissions?

· What is the effective 'carbon price' I need to report?

· Who will check the accuracy of the submitted data and reports?

· Is it possible to correct a previously submitted CBAM report?

· Should the report be in English only or is it possible to report in other languages?

· Reporting: CBAM Provisional Registry

· What is the CBAM Provisional Registry?

· What will the CBAM Provisional Registry be used for?

· Is the CBAM Provisional Register the same as the EU Customs trade portal?

· Will the data shared in the CBAM Provisional Registry be treated confidentially?

· How can I register as a declarant and access the CBAM Provisional Register?

· Who is authorized to register a company as a CBAM Declarant?

· Who can complete the CBAM notification in the CBAM Provisional Register for the notifying declarant?

· Can companies that are not directly subject to CBAM also access the CBAM Provisional Register?

· How should I fill in the data in the CBAM Provisional Register?

· Methodology for calculating embodied emissions in CBAM products during the transition period

· What is the relevant time period for calculating embodied emissions? Can data from previous years be used?

· What are simple and complex products?

· What are direct and indirect emissions?

· What is the "bubble approach" and how does it work?

· If an imported CBAM product uses precursors from the EU