Final Text of the CBAM Regulation ("Carbon Tariff")

In May 2023, the Regulation EU 2023/956, which introduces the so-called Carbon Border Adjustment Mechanism (CBAM), a system of certificates offsetting greenhouse gas emissions from the production of selected imported goods, was issued. Imports in this case refer to products from outside the EU (excluding Iceland, Liechtenstein, Norway, Switzerland and other selected territories).

The CBAM will only apply to imports of selected goods, namely cement, electricity, fertilisers, iron and steel, hydrogen and aluminium. However, an extension of the scope in the following years cannot be ruled out.

The Regulation introduces new requirements in particular for importers of selected goods. Importers (or their representatives) will have to collect data already this year and report quarterly from 1 October 2023 on GHG emissions released during the production of imported goods and on the carbon price paid abroad (the deadline for the first report is 31 January 2024).

Starting in 2026, importers will be required to pay for the emissions embedded in imported goods via CBAM certificates on a regular annual basis. The price of these certificates will be derived from the existing EU Emissions Trading Scheme (EU ETS).

In relation to the CBAM requirements, ARM can offer cooperation in the following areas:

• draft / consultation of methodologies for calculating emissions from imported goods
• development of a calculation tool for determining the magnitude of GHG emissions according to the Regulation EU 2023/956
• assessment of the quality of the collected data
• functional specification and/or development of tools for data collection, archiving and processing
• cooperation in establishing procedures for data collection, GHG emissions calculation and reporting
• draft / consultation of an approach to translate the cost of CBAM certificates into strategies, planning, pricing, risk management, etc.