The Carbon Border Adjustment Mechanism (CBAM) functions through a structured process to ensure accountability and compliance. EU importers of CBAM-covered goods must request data on the carbon emissions embedded in those goods from their non-EU suppliers. Suppliers are required to calculate emissions based on a methodology established by the EU. Once the data is received, importers report these emissions via the CBAM registry. To account for the embedded emissions, importers must purchase CBAM certificates, which are then surrendered to the EU. This approach ensures a level playing field by applying the same carbon price to imported goods as to EU-produced goods.
Why do non-EU operators need access to the CBAM registry?
One significant challenge with implementing CBAM is the collection of emissions data from suppliers outside the EU. For third-country producers, calculating and providing emissions data involves considerable effort, often compounded by varied and uncoordinated data requests from multiple EU importers through different communication channels. To streamline this process, the EU has introduced a CBAM registry for non-EU installation operators. This registry allows suppliers to directly submit their emissions data to the EU. EU importers can then access this centralized data for their CBAM reporting, reducing the administrative burden for both parties and ensuring a consistent flow of data.
How to get access
Non-EU operators can request access to the CBAM registry through a defined process. First, they must create an EU login account, which can be done via a designated link. Using this login, operators can access the CBAM Portal and apply to become a Registered CBAM Operator. After submitting all required information and an access request, the EU will review and approve the application. Upon approval, operators gain access to the portal. When logging in for the first time, operators must submit a registration request, including details about their operations and installation sites.
What can operators do?
Once the registration request is approved, the operator can begin providing emissions data. Using the installation data provided during registration, they can associate specific goods with each production site. This includes submitting essential information such as product details, emissions data, production specifics, and any carbon costs already incurred. Operators can then disclose this data by linking it to the importers’ EORI numbers. This allows importers to access the relevant data directly in the CBAM registry, ensuring seamless reporting and compliance with CBAM requirements.
Advantages of the non-EU operator access
The CBAM portal offers a streamlined process for non-EU operators to share emissions data with their EU customers, eliminating the need for multiple communication channels. This system ensures confidentiality and secure handling of sensitive business data. For EU importers, direct access to emissions data through the registry simplifies the reporting process, particularly for companies managing smaller volumes of goods.
Disadvantages of the non-EU operator access
Despite its benefits, the portal has notable limitations.
The registration process for operators is lengthy and remains relatively untested. In addition, operators must collect and manage EORI numbers for all their EU customers and accurately attribute goods and production processes to the correct EORI numbers. This process also requires operators to stay informed about CBAM updates, a task that not all may undertake proactively. Additionally, the fact that some operators use the portal and others do not can create a confusing situation for everyone.
From an importer’s perspective, the portal adds complexity, as they remain fully responsible for their CBAM reports and must coordinate data collection from suppliers who do not use the portal. They have to ensure that all suppliers using the portal have and declare their EORI number. This already poses high uncertainty. Moreover, the portal’s current structure does not allow for XML-based reporting when using data from third-country operators. This would require additional manual effort and coordination, especially for importers handling large volumes of goods.
The most critical limitation is the timing and location of data availability. Importers have only access to emissions data during the reporting phase and in the CBAM registry. From 2026, when the data will have a direct impact on the number of CBAM certificates, this is an unacceptable situation. The number of CBAM certificates to be purchased has a direct impact on the additional costs of CBAM. In order to adequately assess costs and make informed purchasing decisions, importers need emissions data earlier in the procurement process, which requires additional communication outside the portal. If this data is readily available, the portal would not be necessary for third-party operators.
Conclusion
The CBAM registry access for non-EU operators is a promising initiative but comes with significant limitations. While it facilitates compliance for smaller importers and suppliers with limited transactions, it may not adequately meet the needs of larger operators. For importers dealing with substantial volumes of goods, integrating a dedicated software solution could prove more effective. Such a solution would centralize CBAM data collection, streamline reporting and enable informed supplier decisions, ultimately ensuring cost-effective compliance with CBAM requirements.
