The CBAM report for the third quarter of 2024 should contain actual emissions data. What should companies do if they do not receive data from their suppliers?

The CBAM report for the third quarter of 2024 requires reporting CBAM importers to use actual emissions data for the first time. Previously, it was possible to use default values. There is no extension for the possibility to continue using default values.

Importers must provide evidence of their efforts

Many companies face the challenge that their suppliers in third countries do not provide this data. The EU Commission and the German Emissions Trading Authority (DEHSt) provide information on the correct procedure: Companies must prove that they have endeavoured to obtain actual emissions data for their imports. The evidence must be submitted in the CBAM transitional register via the ‘Comments’ field.

If the actual emissions data is missing from the report, it is considered incomplete. The competent national authorities have the option of imposing penalties. The amount is between ten and 50 euros per tonne of CO2 emissions not reported. DEHSt points out that it will exercise its discretionary powers. The following points will be considered: Importers must prove that they have taken all possible measures to report the actual emissions. They must plausibly demonstrate that all reasonable steps have been taken and that further investigation of the actual data would have been disproportionately costly. In addition, further discrepancies are taken into account in the report.

Source: DEHSt