If you've been asked for CBAM data from your customers, there are some key steps that you need to take in order to be in a position to share data back with them that complies with the EU CBAM requirements on product-level carbon intensity data.
If you'd like to learn more about CarbonChain's simplified CBAM installation reporting service, please see this article and the overview of requirements.
To support other users, CarbonChain has prepared an extensive set of training materials on this Learn platform in order to support your data preparation requirements. These steps below have been prepared in order to walk you through the data preparation process:
First, learn more about CBAM and it's requirements for installations and the data that you are being asked to prepare:
Next, you need to identify which products you produce are CBAM goods as well as which products you buy that are CBAM precursor goods:
If you purchase CBAM precursors, you need to request CBAM data from your suppliers in order to meet the primary data thresholds defined by the EU:
Now you've identified your CBAM goods, you need to prepare your EU CBAM data communication file.
We have prepared extensive guidance in order to support you in preparing this documentation, broken down by product categories:
EU CBAM also requires that you prepare a monitoring methodology in order to document the approach that you take in order to prepare your CBAM data communication file. Monitoring methodology documents will be a key part of verification in 2026 however, they are not required by your customers to meet their reporting obligations to the EU today. You can find additional guidance at each product-level on preparing your monitoring methodology.
What are the key timelines?
For reporting CBAM goods in the EU Transitional registry:
Importers of CBAM goods have to report quarterly (Jan, Apr, Jul, Oct) until Jan 2026.
Importers can use default values for these reports until July 2024.
After July 2024, to import your products without risk of a penalty, importers will require your installation data before the end of October 2024.
And how does this translate to me, as an installation?
You need to share the CBAM installation data with your customers by latest October 2024.
Ideally you share 2022 data immediately and plan to send full year 2023 data by July - covering emissions intensity calculations for the full 12-month period (e.g. 1 Jan to 31 Dec 2023).
You need to implement your monitoring methodology ASAP, and you should have initiated measurements in line with this MMD on the 1st October 2023.
From October 2024 onward, you only have to share data with your customers once per year based on an updated 12-month data set.
In 2026, you will need to have your data verified by an appropriate verification provider - we will learn more about this process from the European Commission in 2025.
Am I even impacted by EU CBAM?
The first key step on to understand if you are impacted by EU CBAM is to assess if you produce any CBAM goods.
What is a CBAM Good?
CBAM goods are defined via their CN (Common Nomenclature) code which is a classification of goods used for customs purposes (also see the HS or TARIC code).
The aggregated goods categories captured under the CBAM regulation are hydrogen, electricity, aluminium, iron and steel, ferroalloys and cement.
CBAM goods are split into two categories: simple and complex goods. Simple goods are minimally processed (e.g. aluminium ingots or sintered ore) whilst complex goods are processed (e.g. aluminium sheets or steel screws).
The definitive list of CBAM goods currently captured under the EU CBAM regulation are in this summary list of CBAM CN codes
Furthermore, the default values provided by the European Commission for each CN code are linked in a file at the bottom of this article.
To learn more about identifying CBAM goods via their classification including TARIC, CN and HS codes please take a look at this article.
When does a good become a CBAM good?
Even if you do manufacture CBAM goods, a reporting obligation only arises where those goods are released for free circulation into the EU. This means that they have been imported into the EU for use, rather than subjected to an inward processing regime.
To learn more about what "release for free circulation" means and further information on customs requested procedures, please see this article.
Therefore, any of the following criteria need to be met in order to determine if you will have to report your installation data to a customer:
You produce a CBAM good and you or your customer (or their onward customers) import and release the CBAM good for free circulation into the EU.
You produce a CBAM good that is a precursor for another non-EU customers' production process and they subsequently export to the EU.
You are EU-based and your CBAM precursor good is exported outside the EU, processed into another CBAM good and then subsequently re-imported into the EU.
In all of the above scenarios, you can expect your customers to request installation data from you in order to meet their CBAM reporting obligation.
Timeline: CBAM goods can be reported using default values until 31 July 2024. From this point, goods imported into the EU will be required to use actual installation data. In this way, your customers will be requesting data to be provided in advance of 31 October 2024. This is the deadline for the quarterly CBAM declaration on goods imported into the EU between 1st July to 30th September 2024.
If you have any questions on understanding if you are impacted by EU CBAM, please don't hesitate to contact support@carbonchain.com