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. You can find the letter templates we recommend sharing with your suppliers attached below. Please amend the header and contact information accordingly.

Yu are looking to obtain a Summary Communication file from each installation that you purchase CBAM precursors from. This looks like this:

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.

If you'd like to use the CarbonChain platform to request and review this data for you then please follow the steps in this article.

For more information please contact support@carbonchain.com

Please see below an outline of a template for requesting embedded emissions data on CBAM goods precursors from your suppliers.

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RE: Forthcoming Request for Carbon Emissions Data to Comply with EU Carbon Border Adjustment Mechanism (CBAM)

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 as we market material into the EU and therefore have a reporting obligation under the EU CBAM. In order to do this, we need you to provide us with emissions data on the CBAM goods you have sold to us as identified by the EU CBAM regulation.

We are working with CarbonChain to collect this data and pass it onto our EU customers. As part of this work, we alongside CarbonChain will be sending you a formal data request within the next 14 days regarding the CBAM Goods you supply.

To meet our compliance requirements, we will 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 an initial guidance to support your reporting.

● We require you to share your CBAM Summary Communication sheet no later than 30th September 2024. Please prepare this data in line with the guidance from the European Commission and, where possible, preparing data for the latest 12-month reporting period.

o Please note that from July 2024, the maximum share of default values in the embedded emissions calculation is 20%. Please ensure that you have shared your CBAM Summary Communication sheet containing at least 80% primary data in advance of this date.

● 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,

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