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period . Penalties can be imposed in cases where the reporting declarant fails to submit a correct or complete CBAM report or doesn ’ t rectify errors when initiated , with penalties ranging from 10 to 50 euros per tonne of unreported emissions .
What are the immediate tasks for companies ?
The definitive period is two years away , however , here are the preparations companies should conclude at once to comply with the legal obligations of the transitional period and to get a head start for the definitive period :
• Identify which of your imports are subject to CBAM regulations . Engage with suppliers and manufacturers to gather emissions data for imported goods . Collect information on carbon pricing schemes in countries of origin for your CBAM goods .
• Get registered as a CBAM declarant or have your indirect customs representative get registered .
• Get access to the transitional CBAM registry . This is the interface for regulators and regulated entities for the transitional period .
• Learn how to handle the CBAM reporting template published by the EU .
About the authors
Simon Göß is an energy engineer , expert on energy and carbon markets and managing director at carboneer . He led consultancy projects , studies and more than 150 workshops and trainings on energy and carbon markets , trading and policy .
• Establish processes to collect emissions data and set aside personnel capacities to handle CBAM duties .
• Make use of the EU ETS allowance price forecast and embedded carbon projections to assess the medium-term economic implications of CBAM regulations on your supply chain and business .
• Understand the implications of CBAM on your supply chain and assess your price and regulatory risk in different countries .
With the introduction of CBAM , emission monitoring and reporting along with carbon pricing plays an ever more important role for non- EU producers and importers . While the emission reporting
Hendrik Schuldt is an environmental economist , climate policy advisor and managing director at carboneer . He previously worked at the Potsdam Institute for Climate Impact Research ( PIK ) and still heads the non-profit climate protection organisation Compensators .
obligations during the transitional period of CBAM are new to many companies and require comprehensive preparation , regulations on CBAM will evolve during the coming years and should be closely monitored by third countries and EU producers as well as traders and importers alike . Details on CBAM implementation rules will for example still be required on the treatment of green electricity procurement through power purchase agreements in third countries or on updated product lists subject to CBAM obligations . Ultimately , companies require a strategic approach towards these new realities of global trade and decarbonization .
Vidovic , D ., Marmier , A ., Zore , L . and Moya , J ., Greenhouse gas emission intensities of the steel , fertilisers , aluminium and cement industries in the EU and its main trading partners , Publications Office of the European Union , Luxembourg , 2023 , doi : 10.2760 / 359533 , JRC134682 .
18 Green Steel World | Issue 9 | November 2023