Importers have numerous questions and concerns regarding the CBAM mechanism. Below, we highlight the three most common questions we have received from importers of CBAM goods.
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Our supplier does not provide us with emissions data. What can we do?
Importers who do not receive verified emissions data for CBAM goods will use the default values established by the European Commission to calculate emissions. Calculating emissions using default values is simpler, but it usually results in higher CBAM obligations for the importer. Importers should choose between actual and default values based on the amount of CBAM goods they import. For small quantities of imported CBAM goods, the calculation method is not particularly important. For larger quantities, however, it is generally more sensible to use actual values.
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How does the CBAM mechanism treat input materials originating in the EU that are used to manufacture CBAM goods?
If a manufacturer in a third country uses input materials originating in the EU to produce CBAM goods, those input materials are deemed to have zero emissions. However, this does not mean that the manufacturer is not required to report input materials originating in the EU in the emissions report. Therefore, input materials originating in the EU do not increase CBAM obligations, but the input materials used must still be reported.
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Where can I obtain a certificate from an accredited verifier?
When emissions from CBAM goods are calculated using actual data, the calculation must be reviewed by an accredited verifier. Importers can obtain the certificate from the CBAM Registry, but only if the manufacturer of the CBAM goods in the third country is registered there. Otherwise, they can receive it from their supplier. The manufacturer in the third country is responsible for commissioning the accredited verifier. The verifier must physically inspect the production process and the installations where the CBAM goods are produced. Based on the data collected during the on-site inspection, the verifier can confirm or reject the emissions data calculated by the manufacturer. This means that, under the CBAM mechanism, importers do not obtain certificates directly from accredited verifiers.
The list of accredited verifiers in Slovenia will be published by Slovenian Accreditation on its website.
Frequently asked questions summarised and answers prepared by: Mojca Müller, Certified Tax Adviser at SIR
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