Q&A thread: CBAM Definitive Period webinar, post your questions early

Pre-submitting: our steel supplier will only provide emissions data once a year, audited in Q1. Is annual data acceptable for all four quarterly filings, or do we need them to attest it hasn't materially changed?

Question for the session: do we need to purchase CBAM certificates before the October filing, or only hold enough by the surrender deadline? Cash-flow planning depends on this.

Great questions, both queued for Wednesday. Short preview on the annual-data point: yes, with an installation-level attestation of no material process change, I'll show the exact wording we use on a slide.

Pre-submitting: how does the definitive period interact with customs value when the carbon cost is invoiced separately by the supplier? We have two contracts where it lands as a distinct line and nobody can tell me whether it is dutiable.

Also for the session, please: the small-consignment threshold. Does it apply per import or per declarant per year, and does splitting shipments across two entities read as avoidance? Asking for a client who is about to find out the hard way.

Adding a pre-submitted question: for composite goods where only the steel fraction is CBAM-covered, is the emissions calculation on the whole article weight or the covered fraction only? Our supplier's mill cert covers the coil, not the finished bracket.