CBAM: Carbon Border Adjustment Mechanism

  • 18/10/23

On 17 August 2023, the EU adopted an Implementing Regulation on the Carbon Border Adjustment Mechanism (CBAM) that regulates the obligations of importers of certain goods during the transitional period. CBAM will initially apply to the following sectors: cement, aluminium, iron and steel, hydrogen, electricity, and selected fertilizers.

During the transitional period, which lasts from 1 October 2023 to 31 December 2025, importers will only report emissions released as part of the production of imported goods that fall under the scope of CBAM. Reports must be submitted quarterly within one month of the end of a calendar quarter.

If the data is not available, importers may use basic values published by the European Commission for imports made until 31 July 2024.

Since CBAM requires cooperation between a number of company departments, we recommend that importing companies start giving more attention to this issue now.

CBAM after transitional period

After the end of the transitional period, companies will have to pay financial compensation for carbon emissions embedded in imported goods. A company importing the above commodities will have to purchase CBAM certificates, the price of which will reflect EU ETS prices adjusted for all free allowances, which producers receive with regard to EU and carbon costs incurred during the production process in the producing country.

How we can help you - PwC as your partner on the CBAM reporting journey

Our team of subject matter experts is ready to assist you in understanding the obligations arising from the CBAM and in setting up the right processes for collecting the necessary data for your company.

Steps to be recommended

In the first step, an analysis of the goods that are imported by the company and a definition of those that fall under CBAM reporting is carried out. As part of the analysis, the customs classification of the relevant imported goods must be checked.

Output: List of imported goods to be reported and goods for which the customs classification should be confirmed.

The workshop will be a face-to-face meeting lasting approx. 3 hours. The workshop will cover CBAM rules in detail and their implications for companies from the ESG, legal, and tax perspective, etc.

Output: Workshop and suggested next actions.

Analysis of existing contractual relationships between the company and its suppliers / business partners to map the current status and identify obligations at each stage of the supply chain.

Output: Mapping of stakeholders with different competences, and action plan.

Preparation of brief explanatory letters to suppliers explaining the situation and the impact on the business relationship, and preparation of a questionnaire to collect the necessary data for reporting. 

Output: Communication package to be sent to suppliers.

Collaboration on the preparation of the CBAM declaration, including review of the prepared declaration based on the background information.

Output: CBAM declaration ready to be filed.

Developing internal manuals, guidelines and controls regarding CBAM obligations for company’s employees, or modifying contractual terms and conditions with contractors.

Output: Documentation regulating rules, internal procedures and appropriate control mechanisms regarding CBAM, modified contractual terms and conditions reflecting on CBAM requirements.

Planning your next steps

Don’t hesitate to contact us to find out if the mechanism will apply to your company and what you will need to do.

Contact us

Dagmar  Haklová

Dagmar Haklová

Partner & TLP Leader, PwC Slovakia

Tel: +421 911 425 109

Jan Skorka

Jan Skorka

Director, PwC Slovakia

Tel: +421 918 642 128

Erika Vitálošová

Erika Vitálošová

Director, ESG leader, PwC Slovakia

Tel: +421 911 423 309

Boris Školník

Boris Školník

Manager, PwC Slovakia

Tel: +421 904 939 732

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