Up until July 2024, it was possible to fulfil the Carbon Border Adjustment Mechanism (CBAM) reporting obligations, which were introduced as of Q4 2023, based on the default values published by the European Commission (hereinafter: "Commission").
However, as of July 2024, CBAM reporting should be performed based on actual carbon emission data. Economic operators subject to CBAM reporting should obtain the actual emission data from their third-country suppliers.
As anticipated, obtaining the actual emission data for CBAM reporting has proved challenging due to the suppliers' limited knowledge of CBAM rules and their reluctance to provide data.
In light of this, the Commission has published guidelines which outline the possible consequences of performing CBAM reporting after July 2024, based on the default values of the Commission.
Pursuant to these guidelines, and considering that CBAM reports for Q3 2024 must rely on actual emission data, it is advisable to start gathering this information as soon as possible.
As for the currently ongoing but so far unsuccessful emission data requests, it is advised to review, from a CBAM point of view, whether the economic operators have taken all available and necessary measures to enable the CBAM reporting based on the actual emissions data.
KPMG is happy to support and assist you in obtaining the carbon emission data necessary for CBAM reporting, as well as in the performance of the CBAM reporting based on the acquired actual carbon emission data.
