Day: January 28, 2024

Who must file the report? Defining the CBAM Role

With the first reporting deadline for the Carbon Border Adjustment Mechanism (CBAM) literally around the corner, due on January 31st, it is crucial for importers and representatives to clearly determine who bears the responsibility for submitting the CBAM report, both in the short and in long term.

Before diving into the main topic of this blog, it is worth mentioning that the first three reports – the third due on July 31st, 2024 – are simplified versions, as purely based on data retrievable from the customs declarations and the official EU default values. Starting from the report due on October 31st, 2024, supplier engagement data such as contact details and real factory emission intensities will become mandatory. While importing companies might currently prefer to outsource their CBAM reporting to their direct or indirect representatives, the supplier engagement, probably the most time-intensive part, might still lie under their responsibility.