top of page

Navigating the Transition: A Guide to EU’s CBAM Reporting Rules

More ESG Research and Insights are Available from GC Insights Contact: for more information.

EU Commission adopted Regulation (EU) 2023/956 - the rules for reporting obligations during the transitional period of the carbon border adjustment mechanism (CBAM) from October 2023 until the end of 2025.

During the transitional period, importers or indirect customs representatives are to report on the quantity of imported goods, direct and indirect emissions embedded in them, and any carbon price due for those emissions, including carbon prices due for emissions embedded in relevant precursor materials.

The first report should be submitted by January 31, 2024, in respect of goods imported during the fourth quarter of 2023. The last report should be submitted by January 31, 2026, in respect of goods imported during the fourth quarter of 2025.

The system boundaries of production processes, including emissions data at the installation level, attributed emissions of production processes, and embedded emissions of goods should be used for determining data to be provided for the purpose of fulfilling the reporting obligations. For those obligations, the importers and indirect customs representatives should ensure the availability of information needed from the operators of installations. That information should be received in a timely manner for the importers and indirect customs representatives to fulfill their reporting obligations. That information should include standard emission factors to use for calculating direct embedded emissions, notably fuel emission factors process emission factors, and reference efficiency factors for electricity and heat production.

For a limited period, until July 31, 2024, reporting declarants that would not be able to obtain all the information from third-country operators to determine the actual embedded emissions of the imported goods in accordance with the methodology set in Annex to this Regulation should be able to use and refer to an alternative method for determining the direct embedded emissions.

The reporting obligations should also afford some flexibility for the determination of the production steps in installations that do not account for a significant part of the embedded direct emissions of the imported goods. Such would be typically the case for the final production steps of steel or aluminum downstream products. In that case, a derogation from the required reporting obligations should be provided, and estimated values may be reported for the production steps in installations whose contribution to direct emissions does not exceed 20% of the total embedded emissions of the imported goods. That threshold should ensure sufficient flexibility for small operators in third countries.

GC Insights: During the transitional period, the EU CBAM Reporting Rules have set out the reporting structure required as provided in the CBAM Transitional Registry. The reporting structure (among other supporting information) includes:

  • CBAM goods imported

  • Commodity code, commodity details, country of origin, inward processing information, etc.

  • Goods measure (per procedure: net mass, supplementary units, type of measurement unit)

  • Goods imported total emissions (goods emissions per unit of product, goods total emissions, goods direct emissions, goods indirect emissions, and type of measurement unit for emissions)

  • CBAM goods’ emissions (emissions sequence number, and country of production), installation emissions (installation total emissions, installation direct emissions, installation indirect emissions, and type of measurement unit for emissions)

  • Direct embedded emissions (type of determination, type of determination (electricity), type of applicable reporting methodology, applicable reporting methodology, specific (direct) embedded emissions, other source indication, source of emission factor (for electricity), emission factor, electricity imported, total embedded emissions of electricity imported, type of measurement unit, source of emissions factor value, justification, and Fulfilment of conditionality)

  • Indirect embedded emissions (type of determination, source of emission factor, emission factor, specific (indirect) embedded emissions, type of measurement unit, electricity consumed, source of electricity, source of emissions factor value)

  • Carbon price due (sequence number (type of instrument, description, and indication of legal act, amount of carbon price due, currency, exchange rate, amount in EURO, country code)

  • Goods covered under carbon price due (sequence number, type of goods covered, CN code of goods covered, quantity of emissions covered, quantity covered by free allocations, any rebate or other form of compensation, supplementary information, additional information)

Contact us at to get your business guide to the EU's CBAM reporting rules.

bottom of page