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?
30JulCBAM Definitive Period: What Importers Must File From October
The transition period is over. Walk through the first definitive-period filing, supplier data you must chase now, and what happens if you can't get it.
About this session
What this session covers
The CBAM definitive period changes the game for EU importers of steel, aluminium, cement, fertilisers, hydrogen and electricity. In this session Anna Lindqvist walks through a real (anonymised) first filing: which embedded-emissions data you need from suppliers, when default values are still acceptable, how certificate pricing works, and the three mistakes importers are already making. Bring your own edge cases, the Q&A thread below is open before, during and after the session.
Agenda
- Definitive period vs transition period, what actually changed
- A worked first filing, line by line
- Getting real emissions data out of reluctant suppliers
- Default values, penalties and the enforcement outlook
- Live Q&A from the thread
Session materials
2 filesSupplier emissions data request, template letter
The letter to send now, the one that has actually got data back out of reluctant mills.
cbam-supplier-data-request.docx · 48 KB
Definitive-period filing checklist
Everything the first filing needs, in the order the registry asks for it.
cbam-filing-checklist.pdf · 310 KB
Demo build. Files aren't served yet; the covers are real.
Q&A, ask before the session
Pre-submitted questions get answered first, live.
6 replies
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.
