How to navigate the Carbon Border Adjustment Mechanism (CBAM): A step-by-step guide with best practices

Understanding CBAM and its impact on international trade

The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation designed to address carbon leakage, ensuring that businesses importing goods into the European Union (EU) face the same carbon costs as EU-based companies. CBAM aims to level the playing field by imposing a carbon charge on imports based on their carbon footprint.

The mechanism is applicable to certain goods, such as iron, steel, cement, aluminum, fertilizers, and electricity. If you are an importer or exporter involved in these industries, you must understand how CBAM impacts your business to avoid penalties and ensure compliance.

CBAM is closely linked to EU customs and import regulations. If you're importing goods into the EU, check out our customs clearance guide for the Netherlands to ensure a smooth process.

Why is CBAM important?

Environmental impact

CBAM ensures that companies importing goods into the EU are contributing to the global effort to reduce carbon emissions. It helps prevent carbon leakage, where companies might shift their production to countries with less stringent environmental regulations.

Leveling the playing field

Without CBAM, EU-based companies could face a competitive disadvantage compared to those operating in countries with looser environmental standards. CBAM ensures fairness by imposing carbon costs on imports similar to those borne by domestic producers.

Regulatory compliance

Understanding CBAM requirements and ensuring compliance is crucial for avoiding fines, penalties, and delays in shipments. As the EU tightens its environmental regulations, being proactive in implementing CBAM compliance strategies will be a competitive advantage.

How to comply with CBAM: Step-by-step guide

Step 1: Identify your products affected by CBAM

Not all products are subject to the CBAM charge. The EU has specified a list of high-emission products, such as:

  • Iron and steel
  • Cement
  • Aluminum
  • Fertilizers
  • Electricity
To correctly declare your products for CBAM reporting, you'll need the right HS codes. Learn how to find the correct HS code for your goods to avoid errors in classification and customs processing.

Example: If you’re importing steel from a non-EU country, you must calculate the carbon emissions associated with the production of that steel and report it according to CBAM guidelines.

Step 2: Understand your carbon footprint

For products subject to CBAM, you must calculate the carbon emissions from the production process. The carbon footprint includes direct emissions from production as well as indirect emissions from energy consumption.

Example: If you import cement from a country with high carbon emissions during production, you must accurately assess the total carbon emissions and report them under CBAM. This can be done by obtaining certificates from the producer or using recognized emission factors.

Step 3: Report the carbon content in your imports

Once you have identified your affected products and calculated their carbon emissions, you must report this information to the EU using the CBAM system.

  • The report must include:
    • The carbon content of the imported goods
    • The country of origin
    • The quantity of goods

Do: Always ensure that your carbon content data is accurate to avoid any discrepancies with customs authorities.

Don't: Falsify carbon content data, as this could result in penalties or rejection of your goods.

Step 4: Pay the CBAM fee

Based on the carbon emissions reported, a carbon price will be determined. The EU will charge a fee that aligns with the EU carbon price. For example, if the carbon price is €50 per ton of CO2, you’ll need to calculate how much CO2 your imports are responsible for and pay the appropriate fee.

Example: If you are importing 100 tons of cement with a carbon footprint of 0.9 tons of CO2 per ton of cement, you would need to pay €45 per ton of cement (100 x 0.9 x €50).

Step 5: Ensure continuous compliance

CBAM compliance is an ongoing process. As EU regulations evolve and more products are included in the CBAM scope, you must ensure that your business continuously reports carbon emissions and pays the necessary fees.

Do: Stay updated on the latest changes to CBAM regulations by consulting EU websites and your customs broker.

Don't: Neglect compliance as non-compliance may lead to serious financial penalties or delays.

Best practices for CBAM compliance

  1. Track your supply chain
    • Maintain thorough records of all goods subject to CBAM, including carbon emission data from suppliers. This will make it easier to calculate emissions and comply with reporting requirements.
  2. Work closely with your suppliers
    • Ensure that your suppliers provide accurate carbon emissions data. This might involve requesting certificates or collaborating with them to calculate carbon content.
  3. Invest in carbon reduction initiatives
    • If feasible, work towards reducing the carbon footprint of your imports. This can help lower your CBAM costs and align with global sustainability efforts.
Understanding CBAM is just one part of navigating EU trade rules. If your business regularly imports goods, consider applying for an Article 23 license for VAT deferral to improve cash flow management.

Examples of what to do and what not to do

Do's:

âś” Always ensure accurate carbon content reporting.
âś” Pay the CBAM fee promptly to avoid fines.
âś” Work with an experienced customs broker to handle your CBAM-related paperwork.

Don't's:

âś– Underestimate the impact of CBAM on your bottom line.
âś– Ignore CBAM deadlines for reporting and payment.
âś– Rely on inaccurate or outdated carbon emissions data from your suppliers.

Conclusion

The Carbon Border Adjustment Mechanism (CBAM) is an essential part of the EU's environmental strategy. To avoid penalties and stay compliant, it is crucial to understand CBAM regulations and follow the steps outlined above. By calculating carbon emissions, reporting correctly, and paying the necessary fees, you can ensure a smooth import process.

Maarten de Reij
Logistics partnership manager
Curious what Cargoplot can do for you? Let me know and I will gladly be of service!
Maarten De Reij
Logistics partnership manager
Curious about what Cargoplot can do for you? Or do you directly want to book a shipment. Let me know, I am happy to help!
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