Carbon Border Adjustment Mechanism

[Mathi]

Dear All

Our Europian customer insist to Provide Carbon Border Adjustment Mechanism declaration for our Exports products . What the procedures to give this Declaration? Please explain

[YAGAY and SUN]

If your European customer is asking for a CBAM (Carbon Border Adjustment Mechanism) Declaration, you as the non-EU exporter normally do not submit the declaration directly to the EU authorities. Instead, you must provide emissions data to your EU customer/importer, who files the CBAM declaration.

Procedure for Providing a CBAM Declaration

1. Confirm whether your product is covered by CBAM - CBAM currently applies mainly to:
   • Iron & Steel
   • Aluminium
   • Cement
   • Fertilisers
   • Hydrogen
   • Electricity
     and certain downstream products.
2. Collect Product Emissions Data - For each exported product, determine:
   • Direct CO2 emissions from manufacturing.
   • Indirect emissions (where applicable).
   • Quantity produced and exported.
   • Production route and raw materials used.
3. Calculate Embedded Emissions - Use the EU CBAM methodology or an equivalent accepted method to calculate emissions per tonne or per unit of product. Maintain supporting records and calculations.
4. Prepare a Supplier CBAM Emissions Statement - Include:
   • Exporter name and address.
   • Manufacturing plant details.
   • Product description and HS/CN code.
   • Reporting period.
   • Embedded emissions (tCO2e per tonne/unit).
   • Methodology used.
   • Any carbon tax/carbon price already paid in your country (if applicable).
5. Provide Supporting Documents
   • Energy consumption records.
   • Fuel usage data.
   • Production records.
   • Emission calculations.
   • Third-party verification report (recommended, and increasingly requested by EU buyers).
6. Send the Declaration to Your EU Customer - The EU importer (Authorized CBAM Declarant) uses your data to submit the official CBAM report and comply with EU requirements

Suggested Declaration Wording

"We hereby declare that the embedded greenhouse gas emissions associated with the supplied products have been calculated in accordance with CBAM reporting requirements. The reported emissions data and supporting records are accurate to the best of our knowledge and available for verification upon request."

If you tell me the product name and HS code, I can provide a practical CBAM declaration format/template suitable for your exports.

***

[Ryan Vaz]

As an Indian exporter, you are not directly required to file the CBAM declaration with the EU authorities. The primary legal obligation for filing the CBAM report rests with your EU importer. However, you are required to provide your EU customer (the importer) with accurate and verified data on the embedded greenhouse gas (GHG) emissions of your exported products, as they need this information to fulfil their reporting obligations.

Your EU importer needs information on the "embedded emissions" of the goods you export. This includes:

• Direct emissions: GHG emissions from the production process of the goods.
• Indirect emissions: GHG emissions from the electricity consumed in the production process.
  The emissions are typically measured in tonnes of CO2 equivalent per tonne of product (t CO2e/t product).

  You need to determine the embedded emissions for each type of CBAM-covered product you export.

• Methodology: The EU Implementing Regulation (EU) 2023/1773 specifies the methodologies for calculating embedded emissions. Initially, during the transitional period, companies can use three methods:
  1. EU method: The full methodology set out in the Implementing Regulation.
  2. Equivalent third-country national systems: Methods used in the exporting country if they are equivalent to the EU method.
  3. Other monitoring methods: Including default values, until 31 July 2024. From 1 August 2024, only the EU method or equivalent third-country methods will be accepted.
• Data Collection: This involves collecting data on:
  • Input materials and their embedded emissions.
  • Fuel consumption for production processes.
  • Electricity consumption and its associated emissions factor (grid average or specific supplier data).
  • Production volumes.
• Verification: While not mandatory for the transitional period, it is highly recommended to have your emissions data verified by an independent third party, as this will become mandatory when the financial mechanism starts in 2026.

AI Summary

CBAM declaration reporting places the filing burden on the EU importer, while exporters must provide verified emissions data.
An Indian exporter is generally not required to file the CBAM declaration directly with EU authorities; the reporting obligation rests with the EU importer or authorised CBAM declarant. The exporter's role is to supply accurate and verifiable data on the embedded greenhouse gas emissions of the exported goods so that the importer can complete its reporting obligations. The required information concerns direct emissions, indirect emissions, and supporting records used to calculate embedded emissions for each CBAM-covered product.