Understanding the requirements for reporting on purchased precursors
- Preference for actual data:
- The CBAM regulation strongly encourages the use of actual data from suppliers whenever possible.
- Collecting real data from your suppliers provides the most accurate representation of your product's embedded emissions.
- Use of default values:
- Default values are provided as a fallback option, not as the preferred method.
- During the transitional period (until June 30, 2024), you can use default values for up to 100% of the emissions.
- From July 1, 2024 to December 31, 2025, default values can be used for up to 20% of the total embedded emissions.
- Reporting requirements:
- You must report on all relevant precursors, whether produced within your installation or purchased.
- For purchased precursors, you need to provide information on the country of origin and production routes (if known).
- Steps to take: a) Attempt to collect data from your suppliers first. b) If unable to obtain supplier data, use the default values provided by the European Commission. c) Document your efforts to obtain supplier data and your reasoning for using default values.
- Long-term considerations:
- As CBAM progresses, there will likely be increasing pressure to use actual data.
- Start building relationships and processes with your suppliers now to facilitate data collection in the future.
- Balancing act:
- While it's acceptable to use default values initially, aim to gradually increase the proportion of actual data you use.
- This approach will help you prepare for stricter requirements in the future and provide more accurate reporting.
Remember, the goal of CBAM is to accurately reflect the carbon content of imports. While default values are an option, especially in the early stages, collecting actual data from your suppliers will ultimately provide the most accurate and defensible reporting.