If I sell CBAM-impacted goods to multiple customers in Europe, can I reuse the same CBAM data for all, or does it need to be unique for each customer?

Managing CBAM data reporting for multiple EU customers

  1. Consistency in core data:
    • The fundamental emissions data for your products should be consistent across all customers.
    • This includes data on: a) Direct emissions from production processes b) Indirect emissions from electricity consumption c) Emissions from input materials or precursors
  2. Reusability of data:
    • In principle, you can and should use the same baseline emissions data for all customers purchasing the same product.
    • This ensures consistency in your reporting and reduces the risk of discrepancies.
  3. Product-specific variations:
    • If you produce different variants of a product or use different production processes, ensure you're providing the correct data for each specific product variant.
  4. Time period considerations:
    • Ensure the data you provide corresponds to the relevant production period for each customer's order.
    • While the calculation methodology remains the same, the actual figures might vary if production conditions change over time.
  5. Customer-specific information:
    • Some information might need to be tailored for each customer, such as: a) Order-specific details (quantities, dates, etc.) b) Any customer-specific product modifications that might affect emissions
  6. Reporting format:
    • While the core data remains the same, different customers might request the information in different formats.
    • Be prepared to adapt your reporting format to meet each customer's needs.
  7. Transparency and documentation:
    • Maintain clear records of your calculation methodologies and data sources.
    • Be prepared to explain any differences in reported data, if they occur.
  8. Updates and revisions:
    • If you update your emissions calculation methods or discover any errors, ensure all affected customers are informed and provided with revised data.
  9. Confidentiality considerations:
    • While the emissions data itself can be shared, be cautious about sharing customer-specific information across different clients.
  10. Best practices:
    • Develop a standardized CBAM data reporting template that can be easily customized for each customer.
    • Implement a system to track which data has been sent to which customer and when.
    • Consider creating a centralized database of your CBAM-related emissions data to ensure consistency.
  11. Communication with customers:
    • Proactively inform your customers that you're providing consistent baseline data to all EU clients.
    • Be open to discussing any customer-specific concerns or requirements.

Remember, the goal is to provide accurate, consistent emissions data while also meeting the specific needs of each customer. By developing a systematic approach to CBAM data management, you can ensure efficiency and accuracy in your reporting processes. Always stay updated with CBAM regulations, as reporting requirements may evolve over time.