CBAM Reporting

CBAM started with the iron and steel, aluminium, cement, fertiliser, electricity and hydrogen sectors. The scope is product-based and defined by customs tariff codes, which means that not every product in the same sector is necessarily covered. We run a preliminary check by comparing your product’s code with the scope list.

Under CBAM, the declaration obligation belongs to the importer into the EU or to its indirect customs representative. The authorised CBAM declarant reports the emissions data and required information on the imported goods through the European Commission’s CBAM Registry. For our part, we support you in preparing the necessary emissions data and calculations, in setting up the data infrastructure and in preparing technically for the declaration process.

A corporate carbon footprint is used as a data source for CBAM, but the CBAM calculation is made with a separate method at product and installation level. The two do not replace each other; they feed each other. In short, an existing corporate inventory is a good starting point for installation and energy data, but it does not replace the CBAM calculation.

Extending the scope is under discussion in the EU: adding products with a high steel and aluminium content is on the agenda, and the process has not concluded. Even if your product is not yet covered by CBAM, preparing now can be useful given your export market and your supply chain’s expectations. Because preparing product-level emissions data takes time, early preparation can be an advantage if the scope expands.

The EU allows a carbon price paid in a third country to be deducted from the CBAM obligation. Because Türkiye’s emissions trading system is at a pilot stage, it is not yet clear how far this mechanism will work. Since electricity, cement, steel, aluminium and fertiliser installations can fall under both systems, we set up the monitoring plan and emissions data to serve both.