Do imported CBAM impacted complex goods that contain an input subject to CBAM need to be reported to CBAM?

Understanding CBAM obligations for complex goods with CBAM-regulated components

1. Current scope:
   • As of now, CBAM primarily applies to basic materials and some semi-finished products.
   • Complex or finished goods are generally not directly covered by CBAM in its initial phase.
2. Definition of complex goods:
   • In CBAM context, "complex goods" are those that use CBAM-regulated materials (like steel, cement, or aluminium) as inputs in their production.
3. Reporting requirements:
   • Currently, importers of complex goods that merely contain CBAM-regulated materials as components are not required to report under CBAM.
   • The obligation applies to the direct importers of the basic materials or semi-finished products covered by CBAM.
4. Examples:
   • If you import cars (which contain steel), you don't need to report under CBAM.
   • However, if you import steel sheets to manufacture cars in the EU, you would need to report for those steel imports.
5. Future considerations:
   • The European Commission plans to review CBAM's scope by the end of the transitional period (end of 2025).
   • This review may consider extending CBAM to more downstream products or complex goods.
6. Indirect impact:
   • While you may not need to report directly, be aware that CBAM might indirectly affect the price of complex goods if their manufacturers face increased costs for CBAM-regulated inputs.
7. Preparation steps:
   • Even if not directly impacted now, companies importing complex goods with CBAM-regulated components should: a) Monitor CBAM developments and potential scope expansions. b) Start mapping their supply chains to identify CBAM-regulated materials in their products. c) Consider engaging with suppliers to understand potential cost impacts.
8. Exceptions:
   • Some semi-finished products in certain sectors (like some steel products) are included in CBAM. Always check the specific CN codes to be certain.

Remember, while complex goods are generally not directly covered by CBAM reporting requirements at this stage, it's crucial to stay informed about potential changes and prepare for possible future inclusions. When in doubt, always refer to the official CBAM documentation or consult with the relevant authorities for the most up-to-date information.