How are importers expected to report CBAM data and in what format?

CBAM reporting process and data submission formats

1. Reporting Platform: Importers (or their indirect customs representatives) must submit CBAM reports through the CBAM Transitional Registry, an electronic database set up by the European Commission.
2. Reporting Frequency: During the transitional period (October 1, 2023 to December 31, 2025), reports are submitted quarterly, within one month after the end of each quarter.
3. Access to the CBAM Transitional Registry:
   • Importers need to register with their national competent authority to gain access.
   • The registry is accessible at: https://customs.ec.europa.eu/taxud/uumds/cas
4. Data Input Methods: There are two primary ways to input data into the CBAM Transitional Registry:
   
   a) Manual Entry:
   • Importers can manually fill in the required information directly in the registry interface.
   • This method is suitable for those with fewer imports or less complex data.
   b) XML File Upload:
   • For larger volumes of data or more complex reporting needs, importers can use an XML file upload.
   • This allows for bulk data submission and can be more efficient for frequent reporters.
5. XML File Format:
   • The XML file is a structured data format that allows for organized, machine-readable data submission.
   • It follows a specific schema defined by the European Commission for CBAM reporting.
6. Generating an XML File:
   • The European Commission provides an XSD (XML Schema Definition) file that defines the structure and rules for the XML.
   • Importers can generate XML files in several ways:
     a) Using the supporting XLS file provided on the Commission's CBAM website, which can be used to fill in data and generate XML.
     b) Developing custom software solutions that output data in the required XML format.
     c) Using third-party software tools that support CBAM XML generation, like Emitwise.
7. Required Information:
   
   The quarterly CBAM report must include:
   • Total quantity of each type of CBAM good imported
   • Total embedded direct emissions
   • Total indirect emissions
   • Carbon price paid in the country of origin (if any)
8. Data Verification:
   • During the transitional period, there's no mandatory third-party verification.
   • The European Commission and national competent authorities will review submitted reports.
9. Corrections and Updates:
   • Reports can be corrected up to two months after the end of the reporting quarter.
   • For the first two quarterly reports, corrections are allowed until July 31, 2024.
10. Support and Guidance:
    • The Commission provides detailed user manuals, webinars, and e-learning materials on their CBAM webpage.
    • Sector-specific guidance is available for each CBAM sector (cement, iron and steel, aluminium, fertilizers, electricity, and hydrogen).

Importers should familiarize themselves with the CBAM Transitional Registry user interface and the XML schema if they plan to use file uploads. I

t's advisable to start with manual entry to understand the reporting requirements fully before moving to XML-based reporting for more efficient data submission.