Containerhafen mit Containerschiff – Der CBAM verschärft den Warenimport in die EU durch eine CO2-Steuer © Suriyapong Thongsawang, Getty Images via canva.com
07.11.2023

Fit for CBAM: background, key data and requirements

On October 1, 2023, the CBAM – the Carbon Border Adjustment Mechanism – became mandatory for many companies in the EU. This article will give you a quick overview of how the CBAM works and how you can prepare your company specifically for the new requirement.

To get started: What is the CBAM?

CBAM (“Carbon Border Adjustment Mechanism”) is the official title of the new Regulation EU 2023/956.
To understand the background to this regulation, it is best to go back to 2005.
This was the year in which the European Emissions Trading Scheme (EU ETS) was introduced; the European instrument for implementing the Kyoto Protocol.
In order to actually achieve the climate protection targets set, the EU has adapted the emissions trading system several times – most recently in 2021, as part of the Fit for 55 package.
The EU ETS aims to limit emissions with a cap and trade system.
An upper limit is set for the amount of emissions that companies are allowed to emit.
If these are not sufficient, allowances can be purchased.
This has been a problem in recent years.
In order to avoid the strict EU requirements and the associated costs, some companies have relocated their CO2-intensive production to countries with no or lower CO2 prices.
This phenomenon is also known as “carbon leakage” or “relocation of CO2 emissions”.
The CBAM now wants to counteract this. The goals at a glance:

  • General strengthening of emission reduction measures
  • Encouraging the reduction rather than displacement of emissions in production
  • Protection of companies producing in the EU from competitive disadvantages

After publication on August 17, 2023, the CBAM officially came into force on October 1, 2023.
Anyone importing emission-intensive goods into the EU is now obliged to purchase offsetting CBAM certificates.
For the time being, however, companies are granted a transitional period.
We’ll take a closer look at this in a moment – but first an important question: who does the new CO2 border adjustment system actually apply to?

Who does the CBAM apply to?

CBAM initially affects all companies that import the following groups of goods in pure or processed form from non-EU countries:

  • Iron and steel
  • Cement
  • Fertilizer
  • Aluminum
  • Hydrogen
  • Electricity

The EU reserves the right to adapt regulations and product groups until 2026.
The scope of application will therefore be extended in the future.
The new regulations cover both direct production emissions and indirect emissions from the manufacture of primary products or the electricity required.
In contrast to the recently introduced CSRD, the CO2 border adjustment mechanism does not differentiate between turnover and employee figures.
The new system is therefore mandatory for almost all companies in the manufacturing and production industry, provided they import from third countries.

Infografik: Diese Warengruppen sind vom CBAM betroffen (verarbeitet und in Reinform): Eisen und Stahl, Zement, Düngemittel, Aluminium, Wasserstoff und Strom. Die Pflicht gilt unabhängig von Mitarbeiterzahl und Bilanz / Erlösen.

Are you affected? What your company has to do now

Let’s move on from theory to practice.
After coming into force on October 1, 2023, a transition period began.
During this period, your company is only required to report.
By 2030, all products that are subject to EU emissions trading should be included in the CBAM.

Zeitstrahl: Fristen und Phasen vom CBAM 17.08.2023 Veröffentlichung CBAM-Durchführungsverordnung 01.10.2023 Inkrafttreten, Beginn der Übergangsphase 01.01.2024 Beginn der Berichtspflicht 
01.04.2024 Ende der Möglichkeit, Standardwerte für THG-Emissionen zu verwenden
01.01.2025 Registrierungspflicht für CBAM-Anmelder 01.01.2026 Beginn der Implementierungsphase & Zertifikatehandel

CBAM reporting obligation: requirements and timetable

Until the end of the reporting phase, you are required to create quarterly updated reports on the goods you have imported.

How can I prepare for the CBAM?

Step by step: Which specific goods are subject to CBAM, which are exempt from the mechanism and how you can prepare specifically for your new reporting obligation.

This belongs in the CBAM report

Even if it sounds like a lot of work: Stick to your obligations and check your supply chains.
The CBAM Regulation provides for “proportionate and dissuasive sanctions” in the event of non-compliance.
Even in the transition phase, penalties of 10 to 50 euros per non-reported tonne of CO2 emissions are envisaged.

Das gehört in den CBAM-Bericht: Ab 1.10.2023 Quartalsbericht einen Monat nach Quartalsende. Zu berichten sind Stammdaten Ihres Unternehmens, CBAM-Accountnummer, Anzahl und Art importierter Waren, spezifische CBAM-relevante THG-Emissionen, CO2-Ausgleichspreis im Herkunftsland Ab 31.5.2026: CBAM-Erklärung zum Vorjahr (Startjahr 2026) Zu berichten sind Gesamtmenge importierter Waren, Gesamtmenge grauer Emissionen jeder Warengruppe, Gesamtzahl der CBAM-Zertifikate die den Grauemissionen zugeordnet sind – minus des im Ursprungsland entrichteten CO2-Preises

Compensation obligation and certificate trading

From 01.01.2026, the following applies: All emissions that your company has not yet offset in the country of origin of your goods must now be taxed.
To do this, you first need a CBAM registration authorization for your company’s branch.
Only “approved registrants” will be entitled to purchase certificates and import CBAM goods from 2026.
You can then purchase unlimited certificates for your company on a central platform.
It is up to the applicant to calculate the necessary compensation and purchase a corresponding quantity of certificates.
The price is based on the weekly average price of EU ETS certificates.
In principle, you should always have enough certificates available to offset at least 80 percent of the imported goods.
The certificates are valid for two years and can be surrendered.

How can I prepare for the CBAM?

Step by step: Find out briefly and concisely in the factsheet which specific goods are subject to CBAM, which are exempt from the mechanism and how you can prepare specifically for your new reporting obligation.

The CBAM is here – VERSO helps

As you can see: With the CBAM regulations, your company once again has a lot on its plate.
What is intended to be a sensible and above all important step for the environment and the economy is in practice associated with a lot of bureaucracy and effort – especially when it comes to collecting all the necessary data.
With VERSO, you can avoid the data chaos.
In the CBAM module of the Supply Chain Hub, you can automatically and efficiently record all the data that the new CO2 border adjustment system requires of you.
Watch a free demo now to see how it works:

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.

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