During the transition period of CBAM (1 October 2023 – 31 December 2025), there are no financial requirements, as CBAM certificates are not applicable until the definitive period. Although, you still need to report the following on all imported CBAM goods:
If you fail to report or necessary data is missing repeatedly, you will be fined between EUR 10 and EUR 50 per ton of unreported emissions.
Therefore, we recommend that you register your company for CBAM and start preparing your first CBAM report now.
The first step would be to check if your company and the goods you import fall under CBAM. You will be contacted by the Danish Customs Authority if your company imports CBAM goods. If this is the case, the next step is to register your company for CBAM by assigning roles to your employees on TastSelv Erhverv and give them access to the CBAM register on behalf of the company.
Once you have done this, you can start calculating the embedded emissions of your imported CBAM goods. If you are not able to obtain the information from your suppliers in time, we are happy to disclose that the EU Commission published their default values on 22 December 2023.
There is no quantitative limit to using these default values for the first three quarterly CBAM reports. However, after the first three reports, the default values can only be used on complex goods produced from other CBAM goods, and a quantitative limit of 20% of the total embedded emissions will be applied. Therefore, we recommend that you start reaching out to your suppliers to obtain the actual embedded emissions.
Lastly, when you have calculated all the embedded emissions of your imported CBAM goods, you must submit the first CBAM report no later than 31 January 2024.
If you need assistance or have any questions regarding CBAM and the first CBAM report, you are welcome to reach out to us.