Carbon Border Manager

To best prepare for CBAM compliance, we recommend that you first develop a CBAM compliance strategy that not only ensures that you implement CBAM reliably, but also aims to minimise risks and emissions.   

To do this, analyse and evaluate your current supply chain operations and your company's current carbon footprint. 

Also train and sensitise your employees with regard to compliance with all obligations associated with the CBAM regulation and the reporting requirements. Appoint persons responsible for ensuring compliance with due diligence obligations in accordance with the CBAM and for managing the use and administration of the CBAM software you have chosen. 

Also ensure that your suppliers are aware of the importance of and compliance with CBAM. 

Our experience in implementing the SCDDA and CSDDD indicates that the greatest challenge in complying with due diligence obligations lies in data quality. Along the supply chain, companies typically work with a large number of suppliers whose data must be recorded and processed in accordance with the directives' requirements. The same applies to suppliers' emissions data concerning the CBAM regulation. 

Many companies also face challenges when processing the data, as they often lack the necessary resources and expertise. These include  

• manual data entry of import data by customs authorities, brokers, or SAP, 
• manual data cleansing to extract the relevant goods for CBAM reporting,
• manual consolidation of CBAM data in an Excel format,
• and manual entry and completion of data in the Commission's CBAM portal.  

These challenges result in problems such as difficult-to-access data, lack of automation, inefficient use of time, high susceptibility to errors, and a lack of traceability in the event of data changes.

For legally compliant reporting, you should always ensure a correct database. Our Check Your Value Chain software offers you a CBAM-compliant solution for this: you can use it to determine the CO2 emissions associated with your imported goods and carry out regular audits of your supply chain to check the accuracy of your emissions data.

Also make sure to meet the specified deadlines for CBAM reporting. With CBAM implementation, the deadline for submitting your report is 31 May from 2026. 

Early CBAM preparation and implementation offer several key benefits: 

Improved Data Quality: Establishing robust data collection processes early ensures accurate and reliable data from suppliers. 

Resource and Expertise Optimisation: Allocating resources and training teams in advance helps address the complexities of emissions data processing. 

Reduced Manual Effort: Automating data collection and reporting minimises manual tasks, saving time and reducing the risk of human error. 

Enhanced Compliance: Familiarising with technical requirements like the XML format early on ensures smoother and more compliant reporting. 

If you do not implement the CBAM, you could face fines. By December 2025, a fine of €10 to €50 per tonne of unreported/incorrectly reported CO2 emissions can be expected. With CBAM implementation from 2026, a fine of €100 may be imposed. In addition, there may be interruptions to your supply chain and therefore operational delays. 

Please also note that non-compliance with your obligations can also damage your company's reputation and significantly impair the trust of your business partners and customers.