CBAM reporting in force since 1 October
From 1 October 2023, companies importing selected products from non-EU countries whose production is CO2-intensive (e.g., cement, aluminium, fertilisers, electricity, hydrogen, iron and steel and downstream products such as screws and bolts) are required to report the import of these products and the related carbon emissions for their production (carbon footprint).
For the time being, this only involves the reporting of 'imported carbon emissions' and not the obligation to pay a carbon border tax (on goods subject to the carbon border adjustment mechanism, CBAM). The carbon border tax will have to be paid from 2026.
The reporting period is a calendar quarter, and the report must always be submitted by the end of the calendar month following the end of the given quarter. The first report (for the fourth quarter of 2023) will therefore have to be filed by the end of January 2024 via a special electronic portal.
On its website, the customs administration issued its first brief information in this respect: Reporting Obligation arising from the Carbon Border Adjustment Mechanism | Customs Administration of the Czech Republic (celnisprava.cz). The information specifies who will be covered by the reporting obligation and refers to related European legislation, including a list of products subject to the reporting obligation.
We encourage all companies that may be subject to this reporting obligation to pay close attention to this area. If necessary, we will be happy to help you identify whether this obligation applies to you, what data you will need to request from your non-EU business partners, and how to prepare the report itself.