CBAM Report Checklist

Submit on time and avoid fines
By Nick Ogilvie, CBAM Specialist and Customer Success Manager, CarbonChain

2024 is here and we’re rapidly approaching 31st January… If you or your customers import aluminium into the EU, this date can only mean one thing: the deadline for the first CBAM declaration, covering all goods imported during October, November and December 2023.

If you’re still scrambling for information about your reporting obligations and supplier emissions, don’t panic. There’s still time to get ready — but only just.

We’ve put together a handy 5-point checklist to help.

Feel free to reach out if you need more support or you’d like to use CarbonChain’s software for EU and UK CBAM reporting.

1. I’ve established my reporting obligations. Yes/No

Are you the EU CBAM reporting declarant? That’s the party or person registered to import goods covered by CBAM into the EU, and to fulfil CBAM’s reporting obligations. The declarant can be the importer established in an EU Member State, or an indirect customs representative.

Do:

  • Establish who the CBAM declarant is and, if applicable, discuss the CBAM reporting obligation with your indirect customs representatives;
  • Ensure you have obtained access to the EU Transitional Registry or communicated your access request with the relevant National Competent Authority.

2. I’ve identified my CBAM goods. Yes/No

As a member of ALFED, you produce, manufacture, trade or recycle aluminium, but your business might also deal with other CBAM sectors like steel, electricity, feritilisers, iron, cement and hydrogen.

Do:

  • Check which products are covered by the CBAM against the list of CN codes in Annex I of the CBAM implementing regulation;
  • Track every import from 1 October 2023 that included CBAM-covered products.

💡 Top tip: There are various aluminium products that you might assume are covered by CBAM, which are in fact not covered. For instance, aluminium car doors aren’t covered, but the sheets they’re made out of are. Always check the CN code of the good that actually crosses the border, not the goods it’s made from. Check our guide to CN codes for further information about CBAM products.

CBAM Report Checklist - The Aluminium Federation
CBAM Report Checklist - The Aluminium Federation

Example of aluminium goods included and excluded from CBAM. © CarbonChain

3. I’ve gathered the data I need to prepare a minimum viable submission. Yes/No

At minimum, your report needs to contain:

  • Data identifying the CBAM declarant;
  • Data on the origin, type, quantity of imported goods;
  • Embedded emissions of those goods;
  • Information about carbon prices paid abroad.

In principle your National Competent Authority and the European Commission will check the completeness of data in your declaration against customs data on an EORI (VAT number) basis. Incomplete declarations in January, April and July 2024 could result in fines.

Do:

💡 Top tip: Try to get primary supplier data for the very first report so that you get well versed in providing primary data by the time it becomes mandatory. You can amend your first two submissions until 31st July 2024 if you get better data.

CBAM Report Checklist - The Aluminium Federation
CBAM Report Checklist - The Aluminium Federation

4. I’ve started to map customs data to installations. Yes/No

For your 31st October 2024 CBAM report onwards, you will need to include information about the specific installations that your CBAM goods came from.

Do:

  • Start this mapping process as soon as possible;
  • If feasible, include this information in the first CBAM report that you submit in January 2024. You can amend that report until 31st July 2024.

5. I’ve initiated our supplier engagement strategy. Yes/No

From 31st July 2024, you must use primary installation data in your CBAM reports or you could be subject to penalties. Fines are set to be 10-50 EUR per tonne of misreported emissions.

Do:

  • Identify your CBAM goods suppliers and support them to identify any CBAM goods precursors they purchase;
  • Engage with them early to educate them on their obligations under EU CBAM. Without their primary data within the next year, you won’t be able to import their goods without facing potential penalties.
  • Help suppliers get in a position to share data as soon as possible, by supporting them on implementing the CBAM-approved emissions monitoring methodologies.
  • Request primary installation data from them in line with the EU CBAM data communication template.

💡 Top tip: CarbonChain’s Supplier Engagement solution maps, engages and supports your suppliers to measure and report their emissions in compliance with CBAM.

Make CBAM work for you

As the clock ticks down to the CBAM deadline, remember this: your journey to compliance isn’t just about ticking boxes — it’s the first step toward a more sustainable, competitive future for your business.

Requests will start mounting for your emissions data and financial incentives to reduce emissions are emerging. We recommend using the process of CBAM compliance to do full product carbon footprinting and to set targets to cut emissions. With this transparency and action, you can gain a competitive advantage with customers, protect your supply chains from other emerging carbon pricing schemes, and take up sustainable finance opportunities. CBAM is just the beginning of your low-carbon future.

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