Registration in the CBAM transitional registry
Sustainability
As the European Union (EU) steps up its climate efforts, concerns are rising about carbon leakage, a phenomenon whereby companies move carbon-intensive production outside the EU to avoid strict climate policies. In response, the EU has implemented the Carbon Border Adjustment Mechanism (CBAM), a tool designed to put a fair price on carbon and encourage cleaner practices globally.
MITERD Registration
Companies must comply with MITERD Registration to participate in the CBAM. This process ensures that a price has been paid for the specific implicit emissions of imported goods during their production, thus guaranteeing carbon price equivalence between the EU and imports.
To comply with the obligations during the transitional period of the Carbon Border Adjustment Mechanism (CBAM), it is essential to follow a series of steps to register for the Transitional CBAM Registry. Below is a step-by-step guide to help operators with this process:
1. Access the CBAM Portal (TAXUD):
Log in to the CBAM Portal using your electronic certificate or any means of identification recognised by the Spanish Administration.
2. Select ‘Customs Domain’:
During the application process, it is crucial to clearly indicate the ‘Customs domain’ rather than the ‘CBAM domain’ to ensure correct registration in the CBAM Transitional Registry.
3. Request Access and Registration:
Fill in the application form with the required information, ensuring you provide accurate details about your company and contact details.
4. Use Electronic Certificate or Means of Identification:
Ensure the correct use of the electronic certificate or other recognised means of identification for the access and registration request.
5. Registration Confirmation:
Once the application has been processed, you will receive confirmation of your registration in the CBAM Transitional Registry. This confirmation may include information about your access and the functionalities available on the portal.
6. Efficient Communication:
Take advantage of the features of the CBAM Transitional Registry to communicate efficiently with the Commission, the competent authorities and the customs authorities of the Member States.
It is essential that operators keep up to date with the requirements and specific guidance provided by the Commission during this registration process. In case of doubts or difficulties, it is recommended to consult official sources and seek assistance to ensure correct registration and compliance with CBAM obligations.
Obligations during the CBAM Transitional Period
During the transitional period of the Carbon Border Adjustment Mechanism (CBAM), operators are subject to certain obligations set out in Articles 33, 34 and 35 of European Union Regulation (EU) 2023/956. These obligations are designed to ensure compliance with regulations relating to the import of goods under the CBAM.
Registration with the CBAM Transitional Registry
One of the main obligations during this period is registration with the CBAM Transitional Registry. This registry, developed by the Commission, makes it easier for operators to complete and submit the CBAM report, which is an integral part of their responsibilities under the CBAM. The application for access and registration in the register is made through the CBAM Portal (TAXUD), specifying the ‘Customs domain’. The use of an electronic certificate or any means of identification recognised by the Spanish administration is required. The CBAM Transitional Register enables efficient communication between the Commission, the competent authorities, the customs authorities of the Member States and operators.
Quarterly CBAM Report Submission
The declarant, whether the importer or their indirect customs representative, is required to submit the CBAM report to the Commission on a quarterly basis. This report must detail the goods imported during a specific quarter of a calendar year. The deadline for submitting the CBAM report is one month after the end of the corresponding quarter. This obligation will apply throughout the entire transitional period, i.e. every quarter between 1 October 2023 and 31 December 2025.
Deadlines for submitting the CBAM report
The first CBAM report, which will include imports made between 1 October 2023 and 31 December 2023, must be submitted by 31 January 2024. On the other hand, the last CBAM report, which will cover imports between 1 October 2025 and 31 December 2025, must be submitted by 31 January 2026.
Contents of the CBAM report
The CBAM report must contain detailed information, as specified in Annex Y of R/EU 2023/1773. This includes the total quantity of each type of goods expressed in megawatt hours (MWh) for electricity and in tonnes for other goods. It also details the actual and indirect embedded emissions, the carbon price payable to the country of origin, taking into account any discounts or other forms of compensation.
How can Grup Carles help you develop your emissions reduction strategy?
Although the Carbon Border Adjustment Mechanism (CBAM) represents a new challenge for many companies, at Grup Carles we have extensive experience in implementing sustainability solutions and are ready to help you face these changes. Our team of sustainability consultants is fully up to date on CBAM requirements and ready to apply their expertise to your benefit.
From calculating your carbon footprint to creating Environmental Product Declarations (EPDs), at Grup Carles we specialise in offering comprehensive sustainability-related services. Understanding the importance of measuring and reporting on the environmental impact of products, in this case their carbon footprint, we are committed to helping you comply with CBAM requirements efficiently and effectively.
Our global team of experts will be at your disposal to develop strategies that reduce your exposure to CBAM prices before the 2026 implementation deadline. We are proud to be in this position to guide our clients through the implementation of new CBAM compliance systems and thus reduce their carbon footprint.
At Grup Carles, we not only calculate carbon footprints and create strategic reduction plans, but we also carry out life cycle analyses using specialised software to calculate the carbon footprint of products. Our active dedication to environmental engineering and consulting allows us to offer you customised solutions that fit your specific needs. Trust us to be at the forefront of sustainability and ensure that your company is prepared to successfully meet the challenges of CBAM.
