On 13 June 2023, the European Commission issued a call for views on the rules for the implementation of CBAM during the transitional phase, which starts on 1 October 2023 and runs until the end of 2025.

The proposed regulation specifies the reporting obligations and information required of EU importers of CBAM goods, as well as an interim methodology for calculating embedded emissions released during the production process of CBAM goods. 

During the transitional phase of CBAM, entrepreneurs will have to report the emissions associated with their imports subject to the mechanism, at no additional charge. This solution is intended to allow time for stakeholders to prepare and for the EU authorities to provide the necessary information to refine the final methodology by 2026.

The draft implementing regulation provides for some flexibility within the values used to calculate embedded emissions from imports. During the initial implementation period, stakeholders will have a choice of three reporting methods: 

(a) full reporting under the new methodology (EU method); 

(b) reporting based on the equivalent national systems of third countries; 

(c) reporting based on reference values. 

From 1 January 2025, only the EU method will be accepted.

These reporting methods are intended to give businesses time to adapt to the new EU requirements. The Commission is also developing tools to help importers meet their reporting obligations, as well as guidance and materials to support businesses when the transition mechanism begins. Importers will be asked to collect data for the fourth quarter from 1 October 2023, and the first report will have to be submitted by the end of January 2024.

As part of the transparency of the CBAM implementation process, the Commission consultedan informal group of experts while involving third countries, stakeholders and industry representatives.

[pwc.pl]