Starting in Q3, new CBAM reporting rules require EU importers to submit their CBAM reports based on supplier provided embedded emissions data. However, some of our clients have encountered difficulties in obtaining this information from suppliers. What should be done in such cases?

Here's a brief overview of the EU CBAM 3Q requirements and our recommendations

1. Reporting declarants must undertake all possible efforts to obtain actual emission data from their suppliers or producers of CBAM goods. These efforts will be evaluated by your National Competent Authority.

• Start engaging with suppliers early: request embedded emissions data by sending an official letter /email to a designated supplier contact (template available upon request), have a designated supplier contact formally specified in the contract.
• Keep records of the sent requests: email/letter copies, "read" receipts, other communication.
• Educate your suppliers on how to submit emissions data (record online workshops. Contact us for workshops information).
• Have an obligation to provide emission data in your contracts with suppliers.

2. EU-importers are responsible for submitting accurate data on imported embedded emissions in time. Without supplier-provided data EU-importers may be held accountable and face fines for non-compliance.

Use supplier-provided emission data. If not available, make an effort to assess embedded emissions of imported goods based on available information. Explicitly note this in the CBAM report. Document your approach: values and sources of information used, e.g. emission factors and etc.

Another option is to report using EU-provided default values and provide justification that you have undertaken substantial efforts trying to obtain emission information from your suppliers.

3. Use of default values is limited to only 20% of direct and indirect emissions.

Do not use default values to report on embedded emissions in the same way you may have done this in 2Q of 2024, e.g. without thorough and explicit justification for not reporting actual emissions.

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