1. We identify and define supplier and sub-supplier activities.

Importers are responsible for identifying and detailing its suppliers and sub-suppliers production processes. These “installations” must clarify the specific activities and the scope of the process.

2. We correctly monitor supplier processes and gather relevant emissions data.

For each of the processes, importers are responsible for accurately gathering direct emissions information. This includes direct emissions related to heat flows, waste gasses, electricity produced by the installation and indirect emissions related to electricity consumption.

If a supplier (non-EU producer) uses a CBAM good as input for production, called a precursor, the supplier will have to determine and monitor the system boundaries, the production processes, and routes for the production of that CBAM good. If the supplier buys it from a sub-supplier, the supplier has to make sure that sub-supplier is monitoring and gathering the data. Additionally, importers are responsible for selecting the best monitoring process for each CBAM product.

3. We attribute emissions to each production processes.

The importer is responsible for assessing and computing both direct and indirect emissions from all data collected. This task is tedious and time-consuming, especially when working with numerous suppliers.

4. We integrate precursor embedded emissions.

The importer is responsible for the accuracy of the data and calculations of both “simple” and “complex goods”. If a precursor is involved in the production, this embedded emissions data must also be included in the calculations.

5. We validate the specific embedded emissions of CBAM goods and file the report.

The importer is responsible for the validity of the data and the correct calculation of CBAM embedded emissions reporting.

Once specific embedded emissions for each CBAM product has been concluded, it must be filed (along with the relevant supporting data) with the competent local authority. This may include proof of measure, proof of calculation and proof of payment of Co2 price paid in the country of origin.