FinanceMay 15, 2024

Navigating carbon pricing: Unpacking the EU’s Carbon Border Adjustment Mechanism

This article covers how carbon pricing impacts trade, the CBAM framework, key compliance steps, and how to manage it through corporate performance management. 

When Carbon pricing mechanisms are taking importers by storm. Chief among them is the EU’s Carbon Border Adjustment (CBAM). For the uninitiated, CBAM is the latest installment of global carbon pricing mechanisms that put the polluter pays principle into action. Under CBAM, companies don’t get to sidestep costs by importing cheaper, polluting goods from aboard. CBAM puts carbon costs squarely on the shoulders of the purchasing company, no matter where they’re sourcing from.  

Carbon pricing mechanisms, like CBAM, presents many challenges, from data management and emissions calculations to complex reporting requirements. Critical among them will be weighing the cost-benefit of domestic vs. foreign sourcing, which may involve rethinking critical links of the supply chain. 

To understand what CBAM will mean for your organization, let’s walk through the regulation and explore its impacts on financial processes.  

What you’ll learn 

  • How carbon pricing is reshaping imports and production 
  • Understanding the EU’s Carbon Border Adjustment Mechanism (CBAM)  
  • How CBAM works 
  • 5 critical steps to prepare for CBAM’s full enforcement 
  • The best way to manage CBAM: A corporate performance management approach 

How carbon pricing is reshaping imports and production

Carbon pricing mechanisms are sweeping the global. As of April 1, 2024, there are 75 carbon pricing instruments in operation worldwide, and in 2023, carbon pricing revenues 
reached a record high of $104 billion — according to the World Bank.  

What is carbon pricing? 

In its simplest terms, carbon pricing puts a price on carbon emissions to make it more expensive to operate businesses that use polluting practices. The end goal of carbon pricing mechanisms is to reduce greenhouse gas emissions by disincentivizing companies using “brown” business practices, making carbon-light alternatives more attractive. 

What is the polluter pays principle? 

The polluter pays principle is the environmental equivalent of "you break it, you buy it." In essence, whoever causes pollution should bear the costs of preventing, 
mitigating, or remedying that pollution. Carbon pricing makes polluters financially responsible for the costs of the high emissions products they produce or use, not society at large.  

Types of carbon pricing 

Carbon pricing can be explicit or implicit. Explicit carbon pricing puts the price tag right on carbon emissions, whereas implicit pricing encourages reduction without a direct price tag. 
 
Common forms of explicit carbon pricing are: 

  • Carbon taxes, which impose a fee per ton of emissions. They incentivize emitters to reduce pollution by making it more expensive to pollute. 
  • Cap-and-trade system, or Emissions Trading System (ETS), which sets an emissions limit. This allows entities to buy or sell permits based on their emissions. 
  • Carbon border adjustment mechanisms (CBAM), carbon price on imported goods, which we’ll explore at length in this article. 

Understanding the EU’s Carbon Border Adjustment Mechanism (CBAM)  

CBAM is a global policy tool that places a carbon price on imported goods outside the EU based on the carbon they emit during production. Essentially, CBAM is a tariff levied on goods to ensure EU goods aren’t challenged by cheaper, high-emissions products from aboard.  

CBAM has a few goals: 

  1. To encourage cleaner production practices in non-EU countries 
  2. To align emissions standards where differences occur 
  3. To prevent “carbon leakage” by ensuring imported goods face the same carbon price as EU-produced goods.  

How do CBAM and the EU’s Emissions Trading System intersect? 

CBAM aims to complement and reinforce the EU Emissions Trading System (EU ETS), a cap-and-trade system that limits the amount of carbon emissions domestic companies can produce in the EU. Under the EU Emissions Trading System, companies acquire emissions allowances through grants or purchases. The allowances a company purchases determines the amount of regulated gasses they can emit.  

CBAM uses a similar approach, but applies its carbon tax to imports from non-EU countries entering the EU, whereas the EU ETS applies to intra-EU goods.  

In summary, CBAM applies to imports, and EU ETS applies domestically.  

What is “carbon leakage”?

Carbon leakage is when companies shift production and emissions from a region with strict carbon regulations to a location with more lax rules. CBAM prevents carbon leakage by disincentivizing companies to import cheap, high-emission products from aboard.

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How does CBAM work?

Importers must report GHG emissions involved in carbon-intensive goods they’re bringing into the EU. Emissions will carry a “carbon cost,” helping to level the playing field with EU-produced goods that are already subject to carbon costs under the Emissions Trading System (ETS). 

Sectors impacted by CBAM 

Numerous sectors are impacted by CBAM. CBAM will first apply to products with a high risk of carbon leakage including steel, aluminum, cement, electricity, fertilizer, and hydrogen. 

When will CBAM be fully enforced? 

The transitional phase for CBAM launched back in 2023, Initially, full enforcement was slated to occur January 2026, however, the EU Omnibus Regulatory simplification proposal may postpone the start date until 2027. More on this in the coming section.  

What are CBAM’s transitional phase requirements?

In current CBAM’s transitional phase, which is valid December 31st, 2025, importers no not have to pay a carbon price yet, but they do have to: 

1. Submit quarterly CBAM reports 

Importers have to submit a quarterly report on both direct and indirect greenhouse gas(GHG) emissions resulting from their imports. These include details about: 

  • The declarant and their role in the import process 
  • The imported goods’ originating country and manufacturing facility  
  • The type and quantity of the imported goods  
  • GHG emissions information and any carbon price paid in the originating country 
  • Technical product data that could affect emissions 

2. Register in the CBAM transitional registry

As of January 1, 2025, importers must register with the CBAM transitional registry in order to get guidance on how to make and submit their CBAM report, communicate with the commission, and customs authorities and traders.  

What are CBAM’s definitive phase requirements? 

When CBAM is fully enforced, importers will be obligated to: 

What are CBAM certificates?  

Importers must purchase CBAM certificates to cover the carbon emissions involved in the production of imported goods. To purchase CBAM certificates, importers must: 

  • Report on the emissions associated with the imported goods  
  • Have emissions verified by an independent third-party 
  • Buy CBAM certificates based on verified emissions  

One CBAM certificate equates to one tonne of CO2 emitted in the production of imported goods. The price of CBAM certificates mirrors the EU ETS price, so, in the end, the imported goods have carbon costs equal to domestically produced goods. CBAM certificates will be surrendered annually.  

Remember: CBAM certificates are designed to mirror the EU’s carbon pricing system, EU ETS. The EU ETS sets a limit and allows companies to buy permits/allowances based on their emissions, and CBAM certificates reflect EU ETS pricing, so foreign goods face equal carbon costs.  

How does the EU Omnibus Proposal impact CBAM? 

The first Omnibus Proposal introduced a set of proposed changes to CBAM, with the goal of making compliance more manageable for businesses, especially small importers. The proposal would simplify CBAM compliance for many importers by: 

  • Removing CBAM reporting obligations for small importers bringing in less than 50-tonnes of goods per year, except for electricity and hydrogen 
  • Simplifying emissions reporting and calculations  
  • Deferring the obligation to purchase certificates to cover CBAM goods imported in 2026 to February 2027 
  • Allowing authorized declarants to delegate CBAM declarations to third parties, such as consultants or environmental experts 
  • Revising the ‘80% rule’ for CBAM certificate management, to a ‘50% rule,’ where importers would only need to hold certificates for 50% of their carbon emissions. 
  • These changes are still pending and are not currently enforced, which means companies should continue preparing for CBAM as if full compliance is imminent.  

The state of global CBAM adoption

It’s likely that more countries will adopt CBAM in time, with the EU’s CBAM serving as the benchmark for similar mechanisms around the world. The UK is the first to implement CBAM outside the EU, and is well on its way to formalizing the global policy tool.   

How is the UK CBAM different from the EU CBAM?

The UK’s CBAM is very similar to the EU’s CBAM. The main differences? The UK’s CBAM is tax-based, where the EU’s CBAM is market-based, and the UK’s CBAM also allows for adjustments based on the exporting country’s carbon pricing. 

The UK’s CBAM will have no transitional phase and will be fully introduced on January 1, 2027.  

A complete rundown of details specific to the UK CBAM is listed on Gov.UK

5 critical steps to prepare for CBAM’s full enforcement 

In addition to registering as a CBAM declarant, importers will have to establish solid processes in order to determine the CBAM certificates they’ll need to purchase and produce their CBAM declarations.  

To do this, importers will have to:  

  1. Clarify product classification: Determine which products fall under CBAM scope. 
    To do this, identify their Combined Nomenclature (CN) codes, as listed in CBAM regulation. CBAM applies only to goods produced outside the EU, including goods that underwent substantial processing abroad. 
  2. Create internal awareness: Many purchasing and finance teams lack familiarity with CBAM rules, which increases the risk of missteps and delays in preparation. Educating the teams responsible for purchasing, supply chain, and compliance is critical.  
  3. Implement data governance and workflows: Many importers will have to collect and manage emissions data from a wide range of global suppliers, and coordinate reporting between procurement, finance, sustainability, and logistics teams. 
    Isolated spreadsheets and disconnected information systems will challenge CBAM reporting teams. Not only do they add additional steps to the consolidation process, but points of human intervention (like copy and pasting emailed results or manually rekeying data into Excel, for example) immediately exposes CBAM data to error. Establishing data governance checks, and balances will be critical to ensuring emissions data is accurate and consistent.   
  4. Prepare calculations: Importers must prepare to calculate embedded emissions in alignment with CBAM methods, applying relevant emissions factors for imported goods and determining the number of certificates to surrender. 
  5. Become audit ready: In addition to choosing a third-party to audit emissions, establishing an audit trail will be critical to showcasing how the importer meets EU-approved methodologies and verification standards.   

The best way to manage CBAM: A corporate performance management approach 

Just like financial data, emissions data needs to be consolidated to support planning and reporting processes. By integrating emissions into the corporate performance management processes, you can apply the same rigor to GHG management as you do to managing cash flow. This includes data collection, KPI monitoring dashboards, consolidation roll-ups, scenario planning, pre-built calculations, and much more. 

Whether you’re preparing the quarterly CBAM report, purchasing certificates, or evaluating sourcing strategies, using the same CPM toolset you rely on for other critical business processes ensures you’ll have everything you need to stay compliant with evolving CBAM requirements and cut carbon costs.  

Learn how CCH Tagetik ESG & Sustainability Performance management has everything you need to manage carbon emissions — today and as they evolve.

 

valentina-francesconi
Project Manager - CCH Tagetik

Valentina has more than 6 years of experience in CPM solutions, she has a strong background on financial institutions industries, with a specific focus on Solvency II and IFRS17 implementations.

She is now responsible for the development of the ESG & Sustainability Performance Management for Insurance and corporate industries.

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