國際碳協股份有限公司

FAQ

FAQ about CBAM

You can check through the CBAM section on the Taiwan Green Trade Site.

  • The obligation to declare CBAM reports lies with the importer, and manufacturers or traders must provide CBAM data to importers.
  • In addition, the CBAM Registry will establish an information system by December 31, 2024. This system will allow CBAM product manufacturers from third countries outside the EU to input their CBAM product embedded emissions data. This facilitates EU importers in obtaining relevant information and making declarations independently.

In the CBAM regulations and calculation guidelines, there is no mention of whether outsourced processes should be included in carbon content calculations. However, in accordance with the legislative spirit of CBAM, we recommend reporting truthfully.

  • No, only the CO2 emissions generated from precursor and production processes are considered in the embedded emissions of the product.
  • Additionally, CBAM embedding only includes CO2 emissions from “FIXED” equipment,  the emissions from other mobile equipment do not need to be calculated. For example, emissions from conveyors, pipelines, and other fixed equipment used for transportation need to be calculated, but emissions from mobile equipment such as forklifts are not required. CO2 emissions unrelated to the manufacturing process (e.g., office air conditioning, company cars) also do not need to be included in the embedded emissions of the product.

The CBAM regulations categorize products into “Simple Products” and “Complex Products,” and if the precursor is a complex product, it must be included in the embedded emissions calculation. In fact, whether raw materials need to be included in the calculation can be confirmed based on their product CN Code. If the raw materials you purchase belong to products regulated by CBAM, they must be included in the calculation. Also, be sure to request embedded emissions data for the precursors from your raw material suppliers.

  • Not required. During the CBAM transition period, data does not need third-party verification.
  • Businesses subject to CBAM are encouraged to take advantage of the two-year transition period to progressively institute a verifiable procedure for calculating embedded emissions in line with CBAM guidelines.
  • During the CBAM transition period, importers must report the embedded emissions of CBAM products imported in the previous quarter to the CBAM registry within one month after the end of each quarter, starting from Q4 2023.
  • If you are a CBAM product manufacturer, what you need to do is collect a year’s worth of CO2 emission data from the production of CBAM products, calculate the product’s embedded emissions in terms of tons, and distinguish between direct and indirect emissions.
  • In general, for CBAM reports due in the first quarter of the year, data from the previous year should be used. If such data can only be obtained by the end of January/February, the manufacturer can use data from the previous year. (Currently, CBAM regulations and guidelines do not explicitly specify when to start using the latest data. However, according to CBAM’s FAQ, manufacturers should at least start using data from the previous year in the second quarter.)
  • If the report is not submitted as scheduled during the transition period, fines ranging from 10 to 50 euros per ton of embedded emissions may apply. Importantly, it’s the EU importers who bear the responsibility for reporting and potential penalties. Should your failure to submit CBAM product embedded emissions data lead to penalties for your customers, they may pass on these costs to your company, impacting your reputation.
  • CBAM allows the use of default values published by the EU for quarterly reports from 2023Q4 to 2024Q2, with no quantitative limit. It is recommended that if you cannot complete the calculation of embedded emissions by July 31, 2024, you should still submit the default values provided by the EU to your customers.
During the transitional period, and in line with Articles 11 of the Implementing Regulation, the Commission will conduct a first screening of the CBAM reports, and communicate to the competent national authority a list of incomplete or suspicious reports (i.e. when the Commission has reasons to believe they have failed to comply with the CBAM Regulation). It is then up to the competent national authority to decide whether to initiate a review as well as a potential correction procedure, which may ultimately lead to penalties.

The CBAM Regulation applies to all goods that are imported into the EU, namely released for free circulation in the EU single market.

  • Yes, relevant precursors produced in the EU also need to be accounted for in the determination of the embedded emissions.
  • Note, however, that if a precursor stems from EU production, the carbon price already paid in the EU may also be reflected in the CBAM report. (Find more details on the report of the effective carbon price paid in the Guidance document for non-EU installations Section 6.10.).

The transitional period is a learning phase for everyone, including for Commission services and national competent authorities. If the alternative methods do not meet the standards included in Article 4(2) of the Implementing Regulation, and especially for imports after 30 June 2024, then such calculation method may be rejected. The national competent authority would start a dialogue with the reporting declarant to obtain more accurate data.

Carbon capture and use/storage (CCUS) are techniques that become increasingly available on the markets to reduce carbon dioxide emissions. Such emission reductions can be taken into account when determining embedded emissions in CBAM goods, provided that certain criteria are met. These conditions are spelled out in Annex III, Section B.8.2 to the Implementing Regulation (Section 6.5.6.2 of the guidance provides more explanations). The conditions are essentially that the captured carbon dioxide is used to produce products in which it is permanently chemically bound or that the captured carbon dioxide is transferred to a long-term geological storage site.

Goods subject to CBAM that are imported into the customs territory of the Union are measured in net weight. Thus, also for the calculation of embedded emissions of CBAM goods, net weight should be used.

  • The embedded emissions of such stock items may, for imports until 30 June 2024, be estimated using the default values published by the European Commission.
  • Subsequently, actual data will need to be reported. In the case of lacking data for old spare parts or stock items, data for similar or identical goods could be submitted for imports after 30 June 2024.
  • Specific embedded emissions are generally determined per aggregated goods category, unless different production routes are used in an installation. The aggregated goods categories may cover goods with different CN codes. Within the same CN code, the content of alloying elements or the share of input scrap may vary. Nevertheless, embedded emissions during the transitional period can be reported per aggregated goods category.
  • Operators may voluntarily choose a more disaggregated determination of specific embedded emissions for certain goods or groups of goods.