If I am a supplier selling goods affected by CBAM to traders who then resell them to customers in Europe, does CBAM impact me?

Understanding CBAM implications for upstream suppliers in international trade

1. Direct CBAM obligations:
   • As a supplier not directly importing into the EU, you do not have direct reporting or financial obligations under CBAM.
   • The CBAM reporting and future certificate surrender obligations fall on the entity that declares the goods for import into the EU (typically the importer or their customs representative).

1. Indirect impact:
   • While you don't have direct obligations, you are likely to be indirectly impacted by CBAM.
   • Your EU customers (or the traders selling to EU customers) will need data on the embedded emissions of your products to comply with CBAM.
2. Data requests:
   • Expect to receive requests from your customers or the traders for detailed information on the carbon emissions associated with your products.
   • This may include data on direct and indirect emissions, production processes, and energy use.
3. Competitive considerations:
   • Products with lower embedded emissions may become more attractive to EU buyers, as they will face lower CBAM costs.
   • This could impact your competitiveness in the EU market.
4. Preparation steps:
   1. Develop systems to track and calculate the embedded emissions in your products.
   2. Familiarize yourself with CBAM calculation methodologies for your sector.
   3. Prepare to provide detailed, verifiable emissions data to your customers.
   4. Consider strategies to reduce the carbon intensity of your production processes.
5. Documentation:
   • While you're not submitting reports directly to EU authorities, your emissions data may need to be verifiable.
   • Maintain clear records of your emissions calculations and the methodologies used.
6. Communication with customers:
   • Proactively engage with your customers or traders about CBAM requirements.
   • Understand their needs and timelines for data submission.
7. Long-term strategy:
   • Consider how CBAM might affect your market position and explore ways to maintain or improve your competitiveness.
   • This might include investing in low-carbon technologies or exploring carbon reduction strategies.
8. Potential future impacts:
   • Be aware that as CBAM evolves, there may be increasing pressure on suppliers to provide accurate emissions data.
   • Future expansions of CBAM might affect a broader range of products or change how upstream suppliers are involved.

Remember, while you may not have direct CBAM obligations, your role in providing accurate emissions data is crucial for your customers' CBAM compliance. Preparing for these requirements now can help maintain your competitive position in the EU market and support your customers in meeting their CBAM obligations.