Full Outsourcing of CBAM Reporting
We will provide your company with comprehensive support from the identification of goods subject to the reporting obligation to the submission of a complete report.
CBAM Report
As of October 1, 2023, businesses importing selected products from outside the European Union are required to re-report. The EU's carbon border adjustment mechanism, CBAM (Carbon Border Adjustment Mechanism), has come into force.
The mechanism is governed by Regulation (EU) 2023/956 of the European Parliament and of the Council and Commission Implementing Regulation (EU) 2023/1773 concerning a transitional period which requires importers to submit quarterly CBAM reports. Until the end of 2025, this will be done without the need to pay fees. The target period, during which the submission of annual declarations and the purchase and redemption of an appropriate number of certificates will be mandatory, will start on 1 January 2026.
The introduction of CBAM undoubtedly poses many challenges for the business. Considerations certainly require interpretation and understanding of a number of regulations. In addition, complications arise from the need to estimate the number of CBAM certificates needed along with the analysis of the additional costs associated with their purchase. Another challenge is to work with suppliers who can be located in different parts of the world. This contact is necessary in order to obtain the so-called real data on embedded emissions. In addition, during the target period, these data will have to be verified by an accredited entity. Otherwise, it will be necessary to use default values, which are decidedly less advantageous for importers. Higher embedded emissions mean more cooling certificates, which increases the cost of doing business. Moreover, if the supplier is unable to present the actual values under the question mark, further cooperation may arise. In extreme cases, businesses will have to consider giving up trade.
At VIVERNO we support our clients at every stage of fulfilling their obligations related to CBAM. We assist in the preparation and submission of an application for Authorized Applicant status, as well as in estimating the demand for CBAM certificates with a forecast of the associated costs. We also offer support in assessing existing and potential non-EU counterparties for their ability to comply with regulatory requirements.
The first declaration for 2026 must be submitted by 30 September 2027, and the purchase of certificates for 2026 will be possible from February 2027. From January 2027, at the end of each quarter, importers will have to hold an appropriate number of certificates on their account — covering at least 50% of emissions. Therefore, we recommend that 2026 be treated as a simulation phase, including testing of quarterly data analysis and modeling of the demand for CBAM certificates.
Our Projects
Due to the entry into force of new regulations on imports of high-carbon goods from outside the EU, the customer was obliged to submit CBAM reports. Contact with producers outside the European Union turned out to be an undoubted challenge. VIVERNO's task was to identify goods covered by the CBAM mechanism, to contact suppliers/manufacturers in order to obtain the necessary data and to periodically prepare and submit reports in the interim register.
We would like to express our satisfaction with the cooperation with VIVERNO, which supports us in the field of CBAM reporting. With extensive experience working with clients in the energy and environmental industries, this company offers comprehensive CBAM reporting support, including analysis of customer needs, data collection, calculation and report preparation as required.
In the first place, we conducted an analysis of customs declarations to identify goods covered by the CBAM. We have prepared dedicated materials to facilitate the collection of basic installation data. In addition, we have provided information materials and guides prepared by the European Commission to raise awareness of the CBAM requirements of DOMEX's trading partners.
Thanks to our support, the client was able to submit the report on time according to all the requirements. Currently, we continue to work on obtaining real data so that subsequent reports are based on values coming directly from the manufacturer's installation. Based on our experience in calculating the carbon footprint of a product, in order to improve the process of collecting data on actual emissions, we have developed an individual instruction for the form made available by the EC. In addition, we have prepared an internal policy setting out the principles for the implementation of the CBAM reporting obligation in the organization.
Our realizations
Due to the entry into force of new regulations on imports of high-carbon goods from outside the EU, the customer was obliged to submit CBAM reports. Contact with producers outside the European Union turned out to be an undoubted challenge. VIVERNO's task was to identify goods covered by the CBAM mechanism, to contact suppliers/manufacturers in order to obtain the necessary data and to periodically prepare and submit reports in the interim register.
We would like to express our satisfaction with the cooperation with VIVERNO, which supports us in the field of CBAM reporting. With extensive experience working with clients in the energy and environmental industries, this company offers comprehensive CBAM reporting support, including analysis of customer needs, data collection, calculation and report preparation as required.
In the first place, we conducted an analysis of customs declarations to identify goods covered by the CBAM. We have prepared dedicated materials to facilitate the collection of basic installation data. In addition, we have provided information materials and guides prepared by the European Commission to raise awareness of the CBAM requirements of DOMEX's trading partners.
Thanks to our support, the client was able to submit the report on time according to all the requirements. Currently, we continue to work on obtaining real data so that subsequent reports are based on values coming directly from the manufacturer's installation. Based on our experience in calculating the carbon footprint of a product, in order to improve the process of collecting data on actual emissions, we have developed an individual instruction for the form made available by the EC. In addition, we have prepared an internal policy setting out the principles for the implementation of the CBAM reporting obligation in the organization.
What do our customers say?
VIVERNO has specialists with extensive knowledge of EU climate policy and other climate change regulations, which allows them to effectively advise the client on CBAM reporting. Each activity is characterized by full professionalism and scrupulousness in the implementation of the assigned tasks. In addition, their commitment is invaluable. Therefore, we can definitely recommend VIVERNO as an excellent business partner for anyone who is looking for a reliable contractor with a passion for what he does. We highly recommend their services and wish them further success in their business.
Barbara Maruszewska
Chief Financial Officer
Cooperation with VIVERNO was characterized by a high level of professionalism, reliability and in-depth knowledge of CBAM regulations and their practical application. We were provided with comprehensive support in the process of implementing the obligations arising from the mechanism of application of prices at the borders taking into account CO emissions2, which enabled our organization to prepare reports and implement the necessary procedures in a timely and compliant manner. In addition, the team of specialists demonstrated not only substantive knowledge, but also timeliness and flexible approach to the specific needs of our organization. Bearing in mind the high quality of services provided and the professionalism of the VIVERNO team, we strongly recommend this company as a reliable and competent partner in the area of CBAM reporting.
Piotr Pitulski
Co-founder and Co-owner of MTL
Marcin Milczarski
Expert in ESG and sustainability, he specializes in strategic and reporting consulting and business linking environmental and social issues (green transformation, risk aggregation, degrowth vs. decoupling). Author of studies in the field of non-financial disclosures, legal-business relations and implementation of ESG strategies. Expert of the Climate Leadership program conducted by UNEP/GRID-Warsaw, academic lecturer. He combines more than 15 years of professional experience in ESG consulting, sector III, academia and marketing/communication.
Do you have any questions? We have the answers!
Which industries have we already worked with in CBAM?
Our cooperation covers a wide range of sectors. We have cooperated, among others, with the furniture, distribution (chemical products and technical tools and machinery), manufacturing (fittings) and metallurgical industries.
What goods are subject to CBAM reporting?
Annex I to Regulation 2023/956 lists the CN codes for all goods for which embedded emissions are to be reported. Currently, the product groups that are covered by the CBAM mechanism include:
- cement,
- iron and steel,
- aluminum,
- artificial fertilizers,
- electricity,
- hydrogen.
Will the scope of goods covered by the CBAM be expanded?
The European Commission is considering the possibility of expanding the list of goods covered by the CBAM mechanism. However, during the transition period, such changes are not foreseen.
What are the consequences of not submitting a report?
If the report is not submitted, fines may be imposed in the amount of 10 to 50 Euros per tonne of unreported emissions. Any report can be corrected, so even if we do not have all the data at the time of reporting, it is worth sending even an incomplete report, which can be supplemented if necessary.
What is the difference between a transition period and a target period?
For the transitional period, which will last until 31 December 2025, importers are only required to submit quarterly reports, without paying any fees. This is the so-called transition (preparatory) period. For the target period starting on 1 January 2026, importers will be required to obtain authorised declarant status and will be required to submit annual declarations on imported goods from outside the EU and the emissions embedded in those products. In the target period, it will also be necessary to account for emissions with the appropriate number of certificates.
How do you get real data from your suppliers?
The European Commission has prepared a spreadsheet to facilitate the exchange of information between the importer and the manufacturer. A guide for manufacturers has also been published, which allows you to familiarize yourself with the CBAM mechanism and the methodology for calculating embedded emissions.
How to identify goods imported from outside the EU covered by the CBAM mechanism?
For this purpose, customs declarations must be verified against the CN codes they contain. Then look for the CN code in Annex I of Regulation 2023/956. If it is on this list it will mean that the goods in question are covered by the CBAM mechanism.
What are the consequences of not having a positive verification of actual emissions over the target period?
In the absence of a positive verification of actual emissions by an accredited body, the default values published by the European Commission should be used. It should be borne in mind that these values are significantly overstated, making them less advantageous for importers. The volume of embedded issues affects the number of CBAM certificates that must be purchased and transferred for redemption.
Who can verify that the actual data provided by the manufacturer are correct?
Actual data will be verified by accredited verification bodies. Prospective verifiers must first apply and obtain accreditation. This process will begin after July 1, 2026.
When do I have to file an annual return?
The annual declaration must be submitted by 30 September of the year following importation. The first declaration for 2026 must be submitted by September 30, 2027. The next declaration for 2027, must be submitted by September 30, 2028.
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