EC allows delayed submission of first CBAM reporting

07/02/24

Now that the inaugural quarterly CBAM reporting period has drawn to a close, CBAM declarants were obligated in January to undertake their initial measures. With an end-of-the-month deadline these declarants were necessitated to fill out their first CBAM report.

Technical issues were affecting the submission of data and reports for the EU Carbon Border Adjustment Mechanism (CBAM) and the Import Control System 2 (ICS2) at the time of the deadline on 31 January 2024. Solutions have been implemented to assist businesses experiencing difficulties, including a new functionality on the Transitional Registry allowing for delayed submission of CBAM reports.

No penalties will be imposed for delayed submission due to technical errors. Reporting declarants without technical issues are encouraged to submit their CBAM reports on time, with the ability to modify and correct reports until 31 July 2024. Technical teams are working to resolve the remaining issues with the system.

The majority of the companies are reporting with default values for now, but please note that the default values can only be used until July 2024, after which reporting with actual values is necessary. After successful submission of the first report, it is important to start preparing for phase 2 and 3, for which you need to gather actual data regarding the embedded emission in the CBAM products imported into the EU.

We have experience in successfully filing the CBAM reports and can help you. We can also help you in preparing for phase 2 and 3 of the CBAM journey. In addition to the requirement to file reports as of today, we suggest that companies are looking ahead at what is coming and review the financial impact that CBAM may have on the costs of doing business. CBAM may impact the value and supply chain and create opportunities in case sustainability ambitions of companies are taken hand in hand with the CBAM (and other EU green deal) requirements.

Contact us

Claudia Buysing Damsté

Claudia Buysing Damsté

Partner, PwC Netherlands

Tel: +31 (0)65 103 04 63

Maxime den Boer

Maxime den Boer

Manager, PwC Netherlands

Tel: +31 (0)62 053 05 41

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