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Reporting & Disclosures
EU Carbon Border Adjustment Mechanism (CBAM)
CBAM — established under Regulation (EU) 2023/956 — introduces a carbon price on imports of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen into the European Union, based on embedded greenhouse gas emissions. A transitional period (October 2023 – December 2025) requires quarterly CBAM reports. The definitive phase begins 1 January 2026, when importers must purchase CBAM certificates and surrender them annually.
Non-EU exporters in covered sectors must provide verified embedded emissions data to their EU importers, calculated in line with Commission Implementing Regulation (EU) 2023/1773, which specifies default and actual emissions calculation methodologies. Importers must be authorised as CBAM declarants and register on the CBAM Registry administered by the European Commission. Without accurate embedded emissions calculations and structured reporting, exporters risk financial exposure for their EU customers, loss of contracts, and exclusion from EU supply chains.
Our approach
A structured CBAM compliance programme is designed and delivered covering all stages from applicability assessment through to embedded emissions calculation, verification support, and reporting system development. Embedded emissions are calculated in line with Commission Implementing Regulation (EU) 2023/1773, drawing on GHG Protocol methodology and ISO 14064 for boundary and allocation decisions. The objective is to ensure accurate, verifiable embedded emissions data that enables EU importers to meet their CBAM declarant obligations while identifying cost optimisation opportunities for the exporter.
- Assessment of product coverage, HS commodity code classification, and CBAM applicability under Regulation (EU) 2023/956
- Calculation of direct and indirect embedded emissions per Commission Implementing Regulation (EU) 2023/1773 methodology
- Determination of applicable default values versus actual emissions calculation approach based on data availability
- Development of internal data collection and reporting systems aligned with CBAM Registry submission requirements
- Preparation of CBAM quarterly transitional reports (2023–2025) and annual CBAM declarations (from 2026)
- Support for third-party verification of embedded emissions where required by EU importers
- Identification of production process improvements to reduce embedded emissions and minimise CBAM certificate costs
Outcomes
Full compliance with CBAM reporting requirements under Regulation (EU) 2023/956 and Implementing Regulation 2023/1773
Accurate, verifiable embedded emissions calculations accepted by EU importers and CBAM Registry
Reduced financial exposure for EU customers through lower certified embedded emissions
Structured internal processes for ongoing CBAM quarterly and annual reporting
Continued and strengthened access to EU markets in covered sectors
Speak with an expert
The team can walk you through exactly how EU Carbon Border Adjustment Mechanism (CBAM) applies to your organisation's context and objectives.
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