Carbon Border Adjustment Mechanism: What Chemical Exporters Must Report During the Transitional Phase

ations develop later, reporting requirements already require significant cooperation between EU importers and overseas suppliers.

Which Products Are Currently Covered?

The current scope of CBAM focuses on selected carbon-intensive sectors identified within Regulation (EU) 2023/956.

For chemical businesses, product categories currently covered include:

• Fertilizers, including specified fertilizer products identified within the regulation.

• Hydrogen, where applicable under the published CBAM scope.

• Certain chemical intermediates listed within the legislative framework.

Other sectors also fall within CBAM, but companies should always verify whether individual product classifications are included before preparing reports.

Businesses exporting multiple products into the European Union should review customs classifications carefully because reporting obligations depend on whether products fall within the regulated scope.

What Information Must Be Reported?

Published European Commission guidance explains that importers must report the embedded carbon intensity of covered products.

To support these submissions, non-EU manufacturers may need to provide information including:

• Direct greenhouse gas emissions generated during production.

• Information used to calculate embedded emissions.

• Production facility details relevant to emissions reporting.

• Supporting calculation methodologies where required.

• Other technical information specified in the Commission's reporting guidance.

Accurate production data has become increasingly valuable because importers rely on supplier information to complete mandatory quarterly reports.

Incomplete or inconsistent emissions information can complicate reporting and create additional compliance work throughout the supply chain.

The Importance of Supplier Cooperation

CBAM reporting extends beyond the importing company.

European importers depend heavily on manufacturers outside the European Union to supply reliable emissions data. Without accurate information from production facilities, importers may struggle to meet reporting obligations.

This makes supplier communication a critical part of CBAM compliance.

Procurement teams should establish clear processes for requesting emissions information well before quarterly reporting deadlines.

Developing standardized documentation procedures can also reduce administrative effort as reporting becomes routine.

How Quarterly Reporting Works

During the transitional phase, importers submit CBAM reports to the appropriate European authorities according to the reporting framework established by the European Commission.

These reports include information about imported covered products together with the associated embedded carbon emissions calculated using approved methodologies.

Because reporting occurs every quarter, companies benefit from maintaining continuous records rather than collecting information only at the reporting deadline.

Strong record management also helps verify reported values if additional supporting information becomes necessary.

Consequences of Inaccurate or Missing Reporting

CBAM reporting is a regulatory obligation rather than a voluntary sustainability initiative.

Published Commission guidance and Regulation (EU) 2023/956 establish reporting responsibilities for covered imports during the transitional period.

Failure to submit required information, submitting incomplete reports or providing inaccurate emissions data may expose importers to regulatory consequences under the CBAM framework.

For exporters, providing reliable emissions information supports customers' compliance efforts and strengthens commercial relationships with European buyers.

Building an Effective CBAM Compliance Process

Companies supplying products covered by CBAM can reduce future compliance challenges by strengthening internal reporting systems today.

Practical steps include:

• Identifying products that fall within the current CBAM scope.

• Establishing standardized procedures for collecting emissions data.

• Verifying calculation methods before sharing information with customers.

• Maintaining detailed production and emissions records.

• Coordinating procurement, production and sustainability teams to improve data consistency.

These measures support both regulatory compliance and efficient customer communication.

The Bottom Line for Procurement Teams

The CBAM transitional phase has made carbon reporting an important part of international chemical trade. Importers into the European Union must submit quarterly reports covering the embedded carbon intensity of products within the current scope, creating greater demand for accurate emissions information from non-EU suppliers.

For procurement and compliance teams, preparation begins with understanding which products are covered, establishing reliable emissions data collection processes and maintaining clear communication throughout the supply chain. Companies that build strong reporting systems during the transitional phase will be better positioned as CBAM continues to develop.

Ready to source fertilizers from verified global suppliers? Explore competitive offers on our platform today.