Webinar | CBAM: practical insights and future outlook

19th November 2024
13:00

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From 1 October 2023, importers of certain goods which contain greenhouse gas emissions had to start reporting the Carbon Border Adjustment Mechanism (CBAM) under Regulation (EEC) No 2658/87.  The categories of goods that are covered include: cement, electricity, fertilisers, iron and steel, aluminium and hydrogen.

During 2024, companies which fall within the scope of the Carbon Border Adjustment Mechanism (CBAM) Regulations could submit their reporting in three ways:

(a)     Full reporting according to the new methodology (EU method)

(b)     Reporting based on an equivalent method (three options); and

(c)     Reporting based on default reference value (this ended in July 2024)

-            On the 22 December 2023, the EU Commission had published a document containing “Default values for the Transitional Period of the CBAM between 1 October 2023 and 31 December 2025”.  This may be found at the following link.

As from 1 August 2024, importers must report actual emissions from imported goods instead of default values, necessitating due diligence in obtaining accurate emission data from suppliers to avoid financial penalties for unreported emissions.

As from 1 January 2025, there will be changes to the CBAM obligations as follows:

1.        Only authorized CBAM declarants, either importers or indirect customs representatives, can import goods covered by the CBAM regulation in the EU, requiring importers to apply for this status.

2.        Only the EU method will be accepted (as per (a) above)

3.        For complex goods, estimates (including default values) can only be used if they account for less than 20% of the total embedded emissions.

4.        CBAM declarants will be able to apply for the ‘authorised CBAM declarant’ status via the CBAM Registry. Their application will be processed by the National Competent Authority of the EU Member State where they are established. This status will become mandatory as of 1 January 2026 for the import of CBAM goods in the EU customs territory. 

During the transitional period ending 31 December 2025, reporting shall be done by the importer or, in the case of an importer established in a Member State of the EU appointing an indirect customs representative, and where the indirect customs representative so agrees, the indirect customs representative. Where the importer is not established in a Member State of the EU, the reporting obligation shall apply to the indirect customs representative.

When the definitive system will enter into force, each authorised CBAM declarant shall submit, to the European Commission, an annual report on the total quantity of each type of goods imported during the preceding calendar year, total embedded emissions in the those goods, the total number of CBAM certificates to be surrendered corresponding to the total embedded emissions reported, and copies of verification reports issued by accredited verifiers. This report should be submitted by 31 May of each year, and for the first time by 31 May 2027 for the year 2026.

All the processes during the definitive period will be performed through a CBAM registry that will be established and hosted by the European Commission.

Failure to accurately report emissions or comply with CBAM regulations can lead to revocation of authorized status, preventing further imports of CBAM goods, along with potential financial sanctions ranging from EUR 10 to EUR 50 per ton of undeclared emissions.

To explain further such obligations, Forvis Mazars Group is organising a webinar on the Carbon Border Adjustment Mechanism (CBAM) on Tuesday, 19 November 2024 at 13.00h CET.

During the webinar, we will discuss the CBAM report submission procedure with regard to importers, authorised entities, and customs representatives.

You will gain insights into potential expansions of CBAM-regulated goods and understand the CBAM authorised declarant status and its implications. We will also cover third-party verification and installation registration requirements as CBAM becomes fully operational, and explain the quarterly reporting and annual declaration requirements for importers of CBAM-regulated goods. Additionally, we will provide detailed knowledge about CBAM certificates and their requirements.

This webinar is targeting all internationally operating companies, especially those importing goods into the EU, and will feature speakers from major importing countries such as Germany, Romania and the Netherlands.              

If you are interested in attending this webinar you may submit your registration here.

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