Professional Documents
Culture Documents
CBAM
CBAM
Fallmann, 2009
MRV requirements
Trilogues are ongoing and are likely to change some important details, such as
Distribution of roles between Commission and Member States
Scope of included products; Treatment of indirect emissions
Timing of the start of the CBAM, including phase out of free allocation in the EU ETS
Some elements in this presentation are based on the first discussion note on MRV for
embedded emissions in the CBAM, as shared with the Expert Group on CBAM
Aim of our project:
Support in developing the implementing act relevant for MRV
Development of templates and guidance documents for importers and for operators of installations in third countries
These criteria led to a first list of goods to be The Annex can be amended by implementing
covered, identifiable by the 8-digit CN code acts for avoiding circumvention
(Annex I of the CBAM Regulation)
Countries of origin can be exempted from CBAM Other ETS or carbon pricing is not exempt,
if: but: The effective carbon price paid in the
The EU ETS applies in that country, or a full linking
agreement between the EU ETS and the other countries
country where goods are originating in is
ETS has been concluded; deducted from the CBAM obligation
Or in case of electricity:
No specific exemption for least developed
Country has electricity market integrated with Union
internal market countries
Agreement to apply Union law infield of electricity market,
incl. renewables
Main legislation is implemented
Country has submitted a roadmap for these measures
Has committed to carbon neutrality by 2050 under
UNFCCC
Etc.
Verification Contract Unknown
3 Emissions
3 data Use of
VR
Verification report (VR) default value
3 Operator of
and emissions report 4
non-EU installation
VRs VRs
Import of
4 4 goods
6 1
7 Uses data
Access Verifier
data
4
Authorised
Competent Authority
Member State
4 Annual CBAM declaration declarant 1
(in EU)
Customs
declaration
Reviews CBAM declaration 6 2
European
Commission Import of
goods
1
Request data
on embedded
emissions 3
Quarterly reports on
4 embedded emissions
Customs
declaration
Competent Authority
Importer 2
Penalty possible
Member State(s)
2 Information of import
👮 Customs
officer
Responsible for “paying” the CBAM obligation: An After the testing period (from 2026 onwards)
importer with seat in the EU The AD must ensure that it has sufficient CBAM
(‘the authorised declarant’ – AD), who must seek certificates available (purchased from the CA)
authorisation in its Member State (MS) before Every 31 May, the AD surrenders CBAM certificates in
carrying out imports line with the embedded emissions of imported goods
Every 31 May of the following year, the AD must The CA may review the CBAM declaration (during up to 4
submit a ‘CBAM declaration’ to the Competent years following the submission) and correct the
Authority (CA) in the MS, containing: emissions for which certificates have to be surrendered
Total quantity of goods (or electricity) imported The same penalty as under the EU ETS is due (100€ per
Total ‘embedded emissions’ of those goods
t CO2 not surrendered), plus surrender of the missing
certificates
Total number of CBAM certificates to be surrendered (if
applicable, taking into account the carbon price already payed in Certificate price = weekly average of EU ETS allowances
country of origin minus any free allocation) (EUAs)
During the transitional phase, the reports shall be Certificates not tradeable!
due every quarter of a year, with different content
(incl. indirect emissions), not verified
The customs authorities ensure that The embedded emissions shall be based on
Only imports by authorised declarants are actual emissions data. If they cannot be
allowed; adequately determined, use default values
For each imported quantity of a good, the (For Electricity: Default values mandatory,
following data are forwarded to the CA: except if justified to use actual data)
ID of the declarant
Default values will be determined by the
8-digit CN code* of the good imported
European Commission based on public
The quantity of the good
Heat – included
GHG
Emissions
No embedded
emissions
GHG
Emissions
Precursor
emissions
Direct
emissions
GHG
Emissions Other GHG
Precursors
Emissions
Raw materials
Other
products
Transitional
phase only
GHG
Emissions System
boundaries
Fuels for CBAM
embedded
Electricity Products under
Emissions
consideration
Indirect emissions
13 | CBAM @ COMPLIANCE CONFERENCE
SPECIFIC EMBEDDED EMISSIONS (SEE) – CALCULATION
𝐴𝑡𝑡𝑟𝐸𝑚𝑔
For simple goods g, as in Commission Proposal: 𝑆𝐸𝐸𝑔 =
𝐴𝐿𝑔
i.e. this is attributed emissions / tonne of product
ALg = the activity level of the installation (i.e. tonnes of good g produced in the reporting period)
AttrEmg = attributed emissions of g in the reporting period
For complex goods g, add (recursively) the embedded emissions of the relevant
precursors:
𝐴𝑡𝑡𝑟𝐸𝑚𝑔+𝐸𝐸𝐼𝑛𝑝𝑀𝑎𝑡
𝑆𝐸𝐸𝑔 = and 𝐸𝐸𝐼𝑛𝑝𝑀𝑎𝑡 = σ𝑛𝑖=1 𝑀𝑖 · 𝑆𝐸𝐸𝑖
𝐴𝐿𝑔
Mi = Mass of precursor (input material) i consumed in the production of 1t of good g
SEEi = Specific embedded emissions of (1t of) precursor i
However, these embedded emissions SEE are only the “rucksack” of emissions carried by the
precursor.
The actual carbon content is the physical amount of carbon going into the process and
contributing to the direct emissions. For the direct emissions all materials and fuels used in the
process have to be taken into account (i.e. monitored and reported), irrespective of whether
they are relevant precursors or not.
Example: Coke
Production of 1 tonne coke produces ca. 0,3 t CO2 – these are the embedded emissions of coke.
Carbon content of coke is ca. 90%, i.e. 1t of coke burnt = ca. 3,3 t CO2 direct emissions
Total contribution of 1t coke to a production process where coke is a relevant precursor: 3,6 t CO2
Hubert FALLMANN
+43-1-31304-5524
hubert.fallmann@umweltbundesamt.at