What is CBAM – Carbon Border Adjustment Mechanism

What is CBAM (Carbon Border Adjustment Mechanism)?

CBAM Services. Bicon Consultants advise companies on meeting CBAM compliances, with quarterly submissions. We go above and beyond CBAM compliances by advising companies on reducing their energy consumption through energy audit services.

Understanding CBAM

Carbon Boarder Adjustment Mechanism (CBAM) is a landmark tool to put a fair price on carbon emissions from energy intensive industries by the European Union. Essentially EU’s new carbon tax. The aim is to prevent carbon leakage by subjecting the import of certain groups of products from non-EU countries to a carbon levy linked to the carbon price payable under the EU emission trading system (ETS) when the same goods are produced within the EU.

CBAM Compliance Implementation

The CBAMs transitional period started on 1st October 2023 and ends on 31st January 2024, during this phase the importers of CBAM goods are required to submit quarterly reports with the following content:

  1. Quantities in which CBAM goods imported during the quarter, specified per country of origin per production site where the goods are produced.
  2. The embedded direct (if applicable, indirect) greenhouse gas emissions thereof;
  3. Carbon price due to country of origin (if applicable).

In case any challenges are faced by the reporting declarant for obtaining emissions data during the transactional period, they have some alternative options for reporting emissions values, the period ends on 31st December 2024, the corresponding monitoring and reporting methods are below:

  1. A carbon pricing scheme where the production site is located
  2. A compulsory emission monitoring scheme where the production site is located
  3. An emission monitoring scheme at the production site which can include verification by an accredited verifier

The full scope of the CBAM regulation will come into force on 1st January 2026. From this date onwards the importers will need to obtain authorization to import CBAM goods, declare every year the quantity of CBAM goods imported into the EU in the preceding year and their embedded greenhouse gas emissions and surrender CBAM certificates to cover the declared emissions.

CBAM Road Map

CBAM-Bicon-2023

Indian Scenario & The Sectors Covered Under CBAM

Currently the followings sectors are covered under first phase of CBAM:

  • Iron & Steel
  • Fertilizers
  • Aluminum
  • Cement
  • Electricity
  • Hydrogen

When it comes to India’s export market, it will have an adverse impact on sectors like iron & steel and aluminium products to the EU. These sectors will face higher scrutiny under the CBAM mechanism. The major exports to the EU are iron ore & steel will face a significant threat due to the carbon ranging from 19.8% & 52.7 %. When it comes to the carbon intensity of Indian products it is significantly higher than that of the EU and many other countries because coal dominates the overall energy consumption. The proportion of coal-fired power in India is close to 75%, which is much higher than EU. The EU has coal-fired power is approximately 15% and the global average is around 36%. The direct and indirect emissions from the production process of Iron & steel and aluminium sectors will become a major concern for the Indian exporter’s market.

The competitiveness of the Indian market with other countries, India doesn’t have any domestic carbon pricing scheme up to date but implementing decarbonization principle can help the along with nations domestic policies like national steel policy, production linked incentive will help to increase production along with reduction in emissions. By adding clean technologies and financing mechanisms will make India’s production sector more carbon efficient.

Products under various sectors, falling under CBAM regulations include:

Iron & Steel Sector

Agglomerated iron ores and concentrates, other than roasted iron pyrites
Pig iron and spiegeleisen in pigs, blocks or other primary forms
Some products under 7205 (Granules and powders, of pig iron, spiegeleisen, iron, or steel) may be covered here
Ferro-manganese (FeMn)
Ferro-chromium (FeCr)
Ferro-nickel (FeNi)
Ferrous products obtained by direct reduction of iron ore and other spongy ferrous products
Iron and non-alloy steel in ingots or other primary forms (excluding iron of heading 7203)
Semi-finished products of iron or non-alloy steel
Stainless steel in ingots or other primary forms; semi-finished products of stainless steel
Other alloy steel in ingots or other primary forms; semi-finished products of other alloy steel
Granules and powders, of pig iron, spiegeleisen, iron or steel (if not covered under category pig iron)
Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, hot-rolled, not clad, plated or coated
Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, cold-rolled (cold-reduced), not clad, plated or coated
Flat-rolled products of iron or non-alloy steel, of a width of 600 mm or more, clad, plated or coated
Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, not clad, plated or coated
Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, clad, plated or coated
Bars and rods, hot-rolled, in irregularly wound coils, of iron or non-alloy steel
Other bars and rods of iron or non-alloy steel, not further worked than forged, hot-rolled, hot-drawn or hot-extruded, but including those twisted after rolling
Other bars and rods of iron or non-alloy steel
Angles, shapes and sections of iron or non-alloy steel
Wire of iron or non-alloy steel
Flat-rolled products of stainless steel, of a width of 600 mm or more
Flat-rolled products of stainless steel, of a width of less than 600 mm
Bars and rods, hot-rolled, in irregularly wound coils, of stainless steel
Other bars and rods of stainless steel; angles, shapes and sections of stainless steel
Wire of stainless steel
Flat-rolled products of other alloy steel, of a width of 600 mm or more
Flat-rolled products of other alloy steel, of a width of less than 600 mm
Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel
Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel
Wire of other alloy steel
Sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel
Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish- plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialised for jointing or fixing rails
Tubes, pipes and hollow profiles, of cast iron
Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel
Other tubes and pipes (for example, welded, riveted or similarly closed), having circular cross-sections, the external diameter of which exceeds 406,4 mm, of iron or steel
Other tubes, pipes and hollow profiles (for example, open seam or welded, riveted or similarly closed), of iron or steel
Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel
Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, lock- gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns), of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel
Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
Tanks, casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
Containers for compressed or liquefied gas, of iron or steel
Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel
Other articles of iron or steel

 

Aluminium Sector

Aluminium powders and flakes
Aluminium bars, rods and profiles
Aluminium wire
Aluminium plates, sheets and strip, of a thickness exceeding 0,2 mm
Aluminium foil (whether or not printed or backed with paper, paper-board, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0,2 mm
Aluminium tubes and pipes
Aluminium tube or pipe fittings (for example, couplings, elbows, sleeves)
Aluminium structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns); aluminium plates, rods, profiles, tubes and the like, prepared for use in structures
Aluminium reservoirs, tanks, vats and similar containers, for any material (other than compressed or liquefied gas), of a capacity exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
Aluminium casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), for any material (other than compressed or liquefied gas), of a capacity not exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment
Aluminium containers for compressed or liquefied gas
Stranded wire, cables, plaited bands and the like, of aluminium, not electrically insulated
Other articles of aluminium

 

Cement Sector

Other kaolinic clays
Cement clinkers
White Portland cement, whether or not artificially coloured
Other Portland cement
Other hydraulic cements
Aluminous cement

 

Fertilizer Sector

Nitric acid; sulphonitric acids
Urea, whether or not in aqueous solution
Ammonia, anhydrous or in aqueous solution
Nitrates of potassium
Mineral or chemical fertilizers, nitrogenous – Except Urea
Mineral or chemical fertilizers containing two or three of the fertilizing elements nitrogen, phosphorus, and potassium; other fertilizers
Except – Mineral or chemical fertilizers containing the two fertilizing elements phosphorus and potassium3.

 

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