CBAM report kicked back over default values, what now?

The registry wants a documented, escalating trail: (1) a formal data request on company letterhead citing the CBAM regulation and the CN codes, (2) at least two dated reminders, (3) evidence you offered the Commission's communication template, and (4) for future POs, a contract clause making emissions data a delivery condition. File all four with your resubmission and defaults are accepted with a justification annex. Emails alone have been rejected; letters with delivery confirmation have not, in my experience.

Adding the contract-clause language to our supplier onboarding pack after reading this. Prevention beats the justification annex.

What passed our registry review: a dated request letter on letterhead citing the specific CN codes, a follow-up at 30 days, a final notice quoting the contract's data clause, and the supplier's written refusal. Emails alone were not enough, but emails plus one formal letter were. Keep them in the entry file, not in someone's inbox.

We put the emissions-data obligation into the purchase terms at renewal and gave a 90-day grace. Two of five suppliers started reporting rather than lose the contract. It is slower than a workaround but it is the only version that survives the next reporting period too.

Naive question from the newer end: if the supplier never answers, does the report just stay flagged, or is there a route to submit with defaults and a documented refusal? I cannot tell from the guidance whether the trail fixes the submission or only your audit position.

One more practical note from the broker side: attach the request trail as a single indexed PDF, not loose emails. The registry caseworkers triage hundreds of these, the ones that read like a file get accepted faster.