CBAM – detailed reporting obligations and new guidance from the European Commission

On 17th August, the European Commission published rules governing the implementation of the CBAM mechanism during its transitional phase. The transitional phase starts already on October 1, 2023 and will last until the end of 2025. During this period, importers will be required to submit quarterly reports on imports of goods covered by the CBAM regime.

The draft implementing regulation released by the European Commission details the transitional reporting obligations of EU importers of CBAM goods, as well as the methodology for calculating embedded emissions released during the production process of CBAM goods under the transitional period. In addition, the EC has also published detailed guidance with a view to help EU importers and third-country producers in meeting their obligations during the transitional period.

Reporting on imports of goods under the CBAM regime

During the CBAM transitional phase, importers will only have to report on the embedded emissions associated with their imports under the regime, with no need to file any financial adjustments.

According to the published regulations, importers will have to indicate in their report information on:

  • the quantity of goods imported, expressed in megawatt hours for electricity and in tonnes for other goods,
  • the type of goods specified by CN code.

Moreover, reporting for embedded emissions will have to include information such as:

  • the country of origin of the imported goods,
  • type of installation where the goods were produced,
  • production routes applied that reflect the technology used to produce goods,
  • production routes applied that reflect the technology used to produce goods and information on the specific qualifying parameters of the selected production pathway for determining the direct embedded emissions;
  • specific direct embedded emissions,
  • an emission factor used for electricity, expressed in tonnes of CO2e per MWh (megawatt hour),
  • data source or methodology used to determine an emission factor for electricity,
  • in the case of steel products, the identification number of the specific steel mill where a given batch of raw materials was produced.

Please note that importers will be asked to collect data for the fourth quarter of 2023 (starting from 1 October 2023) while the first report should be submitted by 31 January 2024.

Report corrections

The declarant will be entitled to revise the submitted CBAM report within two months after the end of the relevant reporting quarter.

Furthermore, the declarant will be entitled to enter modifications to the submitted CBAM reports for the first two reporting periods until the deadline for the submission of the third CBAM report.


The European Commission authorises Member States to apply penalties in the following cases:

  • if the declarant does not take the necessary steps to comply with the obligation to submit a CBAM report, or
  • if the CBAM report is incorrect or incomplete and the declarant fails to take required actions to correct them.

The penalty ranges from €10 to €50 per tonne of unreported emissions.


The Commission currently intends to organise a series of webinars for importers and manufacturers, covering the general obligations for CBAM reporting together with the specifics of each sector. The next webinar concerns aluminium and will take place on 21 September 2023.