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Producers or manufacturers have a special role under CBAM as importers rely on their information to submit the CBAM report or declaration.

What is important right now?

Data Acquisition Challenges and Shifting Focus

For companies involved in the Carbon Border Adjustment Mechanism (CBAM) transitional phase, the accurate acquisition and documentation of Specific Embedded Emissions (SEE) data is crucial. With the current requirement to use real emissions data for reporting, the focus has intensified on ensuring data integrity and accuracy.

  1. Technical Difficulties: Despite the initial technical challenges with the CBAM Transitional Registry, businesses must now ensure timely and accurate data submissions. The European Commission has addressed these issues, but the importance of a reliable IT infrastructure and support systems remains critical​ (Taxation and Customs Union)​​ (KPMG)​.

  2. Use of Real Emissions Data: The transitional phase mandates the use of real emissions data, moving away from the temporary use of default values. This shift necessitates comprehensive and accurate data collection from across the supply chain. Companies must invest in robust data acquisition methods to meet these stringent requirements​ (Home | White & Case LLP)​​ (EY US Home)​.

  3. Monitoring Plans: Establishing a solid emissions monitoring plan is essential. This includes setting up systematic procedures for tracking emissions throughout production and supply chain processes. Companies need to document their methods thoroughly to align with CBAM requirements and ensure compliance. The transitional period offers an opportunity to refine these monitoring plans to achieve the highest standards of data accuracy and reporting​ (LawNow)​.

As we navigate this phase, prioritizing the development and implementation of comprehensive monitoring plans and investing in reliable data acquisition technologies are critical steps. Ensuring robust reporting processes will help mitigate risks and ensure compliance with CBAM regulations. For more details on the latest updates and guidance on CBAM, refer to the European Commission’s official resources and consultancy firms specializing in CBAM compliance.


Producers or manufacturers of goods imported to Europe have certain obligations 

Producers of goods in the scope of CBAM have the following obligations:

  • Emissions Data Sharing: Producers of goods in countries outside the EU may need to provide data on the carbon emissions associated with their production processes. This information would be used by importers to calculate the carbon intensity of imported goods.

  • Carbon Labeling: In some cases, producers may need to label their products with information about their carbon content. This could be similar to nutrition labels but focused on carbon emissions.

  • Carbon Reduction Efforts: To avoid higher costs for their products in the EU market, producers may choose to reduce the carbon emissions associated with their production processes. This could involve implementing cleaner technologies and sustainable practices.

  • Compliance with International Standards: Producers may need to ensure that their production processes align with international standards for carbon accounting and reporting.

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