Ensuring clear communication with your suppliers on the complexities of CBAM will be critical to the process of obtaining data on the embedded emissions of your imported CBAM goods.
Tracking engagement and documenting all responses is critical in order to be able to provide an audit trail of activities to the European Commission in the declaration in October if it has not been possible to obtain primary data from suppliers.
How CarbonChain can support your Supplier Engagement Strategy
There are a number of ways that CarbonChain can support your supplier engagement strategy:
Platform direct requests
Automate the delivery of a letter of obligation and request for installation data to suppliers each quarter (now, in March, June, September) - please see the below template letter.
Knowledge Hub access
We provide access to this CBAM Knowledge Hub for installations to support your suppliers in understanding the regulation and how to do the necessary calculations on a product basis.
Product-level webinars
We host anonymous webinars for your suppliers to guide them through CBAM regulation and how to comply.
Direct calls with key suppliers
We can run 1:1 sessions with key suppliers to educate on CBAM and answer any questions they have, as well as having our office hours available for suppliers with any ad-hoc questions.
Simplified Supplier reporting template and conversion
CarbonChain can provide suppliers with a simplified version of the EU CBAM Installation Communication Data template and convert this back to the required format.
If you'd like to discuss any of these options further, please contact support@carbonchain.com.
Letter Template for Communicating CBAM Obligation - file attached below
Add HEADER
Add Address
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Dear valued partner,
The European Union introduced the EU Carbon Border Adjustment Mechanism (CBAM) as of 1st October 2023. Until the end of 2025, CBAM will be in a ‘Transitional Period’ that imposes detailed emissions reporting requirements on importers of goods covered by the regulation into the EU, so called ‘CBAM Goods’. This is with the intention of, from 2026 onwards during the ‘Definitive Period’, there being a requirement for importers to purchase and surrender CBAM Certificates in accordance with the embedded emissions of the products being imported.
We must comply with this EU legislation, and to do this we need you to provide us with emissions data associated with your CBAM goods as identified by the EU CBAM regulation.
To meet our compliance requirements and to continue to be able to import goods into the EU produced by you, we ask you to:
In line with reporting periods detailed below, provide us with your installation’s completed CBAM Summary Communication sheet (“CBAM communication template for installations”), on a per-installation basis, which contains the necessary primary installation data for compliance with this legislation. This file includes details pertaining to the embedded emissions of the CBAM Goods produced at your individual installation(s), including specific required parameters detailed in the legislation.
Please refer to the European Commission’s (EC) detailed guidance for installations to complete this sheet. It is of paramount importance that you establish a Monitoring Methodology Document (page 100) as soon as possible and perform your emissions measurement in line with the EU CBAM prescribed methodologies. You can find more information in Article 3 (page 5) and Annex IV (page 88) of the EC Implementing Regulation.
If you require any additional information or assistance in establishing a Monitoring Methodology Document or preparing the installation CBAM Communication Summary sheet, our partners CarbonChain can provide guidance to support your reporting.
Timing:
For our April declaration on CBAM goods imported between 1st January to 31st March 2024, we require you to share your installation communication data templates by the following dates:
2Q2024: 1st April 2024 to 30th June 2024, we require your installation communication sheet by 10th July 2024 to meet our reporting deadline of 31st July 2024.
For reporting period 3Q2024, 1st July 2024 to 30th September, we must receive your installation data to comply with the regulation. Please provide your communication sheet no later than 10th October 2024.
If you purchase any precursors that are CBAM Goods, and therefore are producing ‘complex goods’, you will need to engage with your suppliers to obtain primary data to complete your summary communication sheet. The European Commission’s guidance (page 22) outlines your ability to use default values until the 3Q2024 reporting period and, in line with Article 5 of the Implementing Regulation (page 7), you are permitted to continue to use default values for up to 20% of the total embedded emission of your produced CBAM Goods.
The above requests pertain to the ‘Transitional Period’ of the CBAM requirements and are subject to change. This period of the legislation is outlined as a learning period for the EC and the regulation is expected to evolve in advance of the 1st January 2026 entrance of the ‘Definitive Period’. Our requirements may therefore change however, we will ensure timely communication should this be the case.
Thank you for being a valued partner to our business. We understand that both the interpretation and implementation of CBAM is complex. Should you require any assistance in meeting your obligations, or if you are concerned with meeting the above listed timelines and requirements, please do contact us directly. We are confident we can provide the necessary support and guidance.
Yours sincerely,
[insert your name here]