CBAM Report for Steel Construction: An Introduction

  • 8 October 2024
  • Published by: Andreas Janisch
  • Category: Procurement
No comments

What is CBAM and why is it important?

The Carbon Border Adjustment Mechanism (CBAM) is an EU initiative that aims to create a level playing field by aligning the carbon costs of imports with those of products within the EU. The main goal is to prevent so-called carbon leakage, where companies shift production to countries with laxer emissions standards. CBAM is crucial to achieving climate neutrality in the EU by 2050 by ensuring that both EU producers and importers bear the same costs for CO₂ emissions.

Affected products and tariff numbers

CBAM primarily affects emission-intensive industrial products such as steel and aluminum. Specific customs tariff numbers apply to the steel industry, especially in steel construction and steel parts, and are listed in Annex I of the CBAM Regulation. These numbers help companies determine which of their products are affected by the regulations. Currently (as of 10/2024), the following customs tariff numbers are affected in the steel construction sector:

Steel:

  • Chapter 72 (Iron and Steel): Covers almost all products in this chapter with the exception of headings 7202 30, 7202 50 and 7202 70 to 7202 9980.
  • Chapter 73 (Articles of iron and steel): Covers headings 7301 to 7311, 7318 and 7326, excluding headings 7312 to 7317 and 7319 to 7325.

Aluminum:

  • Chapter 76 (Aluminium and articles thereof): Includes headings 7601, 7603 to 7614 and 7616, except headings 7602 and 7615.

General structural steel construction (e.g. hall steel construction, maintenance platforms, platforms, etc.) belong to the customs tariff number 7308.90.98.00.18 and are affected by it.

Parts of machinery and equipment (e.g. conveyor technology) often fall under Chapter 83 and are currently still excluded.

Create CBAM report

E-government solutions are used to correctly report the real emission values ​​for Germany and Austria. Reporting is always possible in the month following the end of the relevant quarter.

CBAM report in Germany

In Germany, the values ​​are reported via the customs portal. Further information can be found here at the help pages of the customs portal.

CBAM report in Austria

In Austria, the values ​​are reported via the USP (company service portal). You can find detailed instructions for downloading here..

Use of default values ​​and their availability

Until 31 July 2024, companies can use default values ​​to simplify emissions reporting. These values ​​are intended as a preliminary estimate to reduce the administrative burden in the initial phase of the CBAM. The European Commission provides these values, which are based on its Website can be read and downloaded. However, after this deadline, companies must report real, actual emission values ​​that reflect the exact emissions of their imported products.

Data collection and dealing with non-cooperative suppliers

Data for CBAM reporting must come from the producers of the imported goods in the country of origin. This includes information on the quantity produced and the associated direct and indirect emissions.

Suppliers often state that the system is still in a transition phase and that standard values ​​can still be used. However, after checking with the Austrian tax office, this procedure is not permitted. As far as is currently known, no official procedure has been established in the case of uncooperative suppliers. The procedure in this case is to be agreed with the tax office (in Austria under cbam@bmf.gv.at) to be clarified. Under no circumstances should standard values ​​continue to be used, as otherwise it will not be possible to assign the cases.

costs of CBAM

The costs incurred through CBAM depend on the specific emissions of the imported products and the current price of emission allowances in the EU Emissions Trading System. From 2026, when importers will actually have to buy allowances corresponding to the emissions of their products, the costs are expected to increase. Current prices for emission allowances can be found on platforms such as the EU Emissions Trading System.

Frequently Asked Questions (FAQ)

  1. What happens if my supplier does not provide emissions data? If suppliers do not provide data, default values ​​could previously be used. This will no longer be permitted from Q3/2025. In this case, contact the responsible authority
  2. How do I find out which of my products are affected by CBAM? Check the tariff numbers of your products against the list in Annex I of the CBAM Regulation, available on the EU website.
  3. How long can I use default values? Default values ​​can be used until July 31, 2024 to facilitate the introduction of CBAM.
  4. How much does it cost to participate in CBAM? The costs depend on the emissions of the imported products and the prices of the emission certificates. These certificates must be purchased from 2026. Before that, there are no costs.
  5. Are there threshold values ​​below which no reporting obligation arises? The reporting obligation arises as soon as you reach a CBAM value of goods of more than €150 during the customs declaration, even if the goods have different customs tariff numbers.

Last revised on October 8, 2024 by Andreas Janisch