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How CBAM-driven reinvention of your supply chain may foster a competitive advantage

Carbon Border Adjustment Mechanism (CBAM) August 27, 2024 | Share Copy Link Link Copied Close CBAM explained Carbon Border Adjustment Mechanisms (CBAMs) address the climate challenge by imposing a carbon price on certain high-emission imports to prevent carbon leakage. These mechanisms encourage global businesses to monitor and reduce carbon emissions across operations while enabling fair competition within and outside the EU. Beyond the initial importers, users of these goods may face higher prices as suppliers pass on CBAM costs, affecting supply chain economics.

Several countries, such as the UK and Canada, are considering adopting CBAM. The EU has already implemented its CBAM, complimenting the EU Emissions Trading System (ETS). EU CBAM applies to goods like cement, steel, aluminium, fertilisers, electricity, and hydrogen. And the European Commision has recently announced that they will review if they will expand the scope to more downstream products. The mechanism is a pivotal element in the growing suite of regulations and policies under the Green Deal, pushing companies towards greener practices and helping them navigate the complexities of the new sustainable business environment in Europe.

EU CBAM commenced in 2023, with the first report due beginning 2024,  and full financial implications starting in 2026 and phasing in until 2034 (whereby it is currently suggested that CBAM certificates should be bought as of 2027). As mechanisms like CBAM become more common, companies must innovate and adapt. Compliance not only aligns businesses with international sustainability standards, but also positions them competitively in a low-carbon economy.

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Transcript Transcript The EU’s Emissions Trading System (ETS) sets a price on carbon emissions. To reduce costs associated with carbon emissions, some industries relocated to outside the EU, leading to so-called ‘carbon leakage’. To counteract this, the EU introduced the Carbon Border Adjustment Mechanism (CBAM). This new regulation aims to level the playing field between EU and non-EU market participants, and to drive emission reductions outside the EU. It sets a price on the embedded emissions of certain goods imported into the EU and requires monitoring and reporting of these emissions.

The goods currently in scope are: aluminium, iron & steel, cement, electricity, fertilisers and hydrogen. The requirement to buy CBAM certificates is suggested to be delayed from 2026 to 2027, giving importers more time to get ready. It’s important to note that the costs related to emissions included in imports from 2026 will still be applicable; they will just be accounted for in 2027. In practical terms, EU-importers will be paying a price for embedded emissions, this will of course also affect suppliers and supply chains in a broader sense.

CBAM presents challenges for exporters outside the EU and importers into the EU, both in terms of costs, but also when it comes to monitoring and reporting emissions correctly, in line with the EU rules. For non-EU suppliers in particular, there is a steep learning curve, as they will need to communicate correct data to their clients in the EU.

However, it also offers opportunities for businesses making efforts to deliver low-emission products, or use efficient technology. They will have a competitive edge against those lagging behind.

While the EU is leading the way with CBAM, other regions, like the UK, are considering similar measures. It's important for businesses to stay ahead of these developments and take action today:

Assess supply chains: Evaluate your supply chains to identify and address significant carbon emissions.

Implement decarbonisation strategies: Adopt technologies and practices that reduce your carbon footprint.

Stay informed and compliant: Keep up with regulatory changes, focus on compliance with reporting requirements, and be prepared for audits.

EU CBAM’s impact on business: how prepared are you?

Use this quick CBAM readiness assessment to understand how prepared your organisation is for the EU CBAM

Do you import goods in scope of CBAM, or do you supply CBAM component materials to your clients that are part of CBAM goods? Goods covered by CBAM: cement, iron (e.g. screws and bolts), steel, aluminium, fertilisers, electricity, hydrogen. The full list can be found in the CBAM regulation’s Annex.

Yes No CBAM will not be directly applicable to your imports. However, stay informed about future updates as the scope of CBAM is expected to expand to include additional goods. Speak with us to learn more. Select your region: Australia Austria Belgium Bulgaria Croatia Cyprus Czech Republic Denmark Estonia Finland France Germany Greece HK/China Hungary Ireland Italy Japan Korea Latvia Lithuania Luxembourg Malta Netherlands Norway Poland Portugal Romania Singapore Slovakia Slovenia Spain Sweden Switzerland United Kingdom United States My region is not listed above

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The CBAM applies to your imports, and you should comply with the relevant regulations to achieve proper carbon cost adjustments. Answer the following questions to discover your readiness level.

Have you conducted an impact assessment to understand how CBAM affects your business operations and costs? Understanding relevant regulatory requirements thoroughly helps achieve compliance and assess costs. Conducting an impact assessment identifies potential cost increases and operational changes due to necessary CBAM regulations.

Yes No Are you aware of the specific documentation and administrative processes required for CBAM compliance? The CBAM regulation includes secondary legislation, templates, and guidance documents. Depending on your territory, follow specific processes with the competent authority for accurate reporting. Awareness of documentation and processes enables compliance and helps avoid penalties.

Yes No Do you have an overview of the data that is required to comply with CBAM and do you have the data available? Readily available data is crucial for accurate CBAM reporting and compliance. Importers must use their import data and collect actual emission data from suppliers. Suppliers must communicate data to clients and sometimes collect it from their own suppliers.

Yes No Have you provided training to your team on CBAM regulations and compliance requirements? Training your team helps them understand their roles in CBAM compliance. You should aim to establish suitable governance structures to maintain compliance over time.

Yes No Have you engaged with your suppliers or, in the case of you being a supplier, with your clients to address the impact of CBAM with them? Communication throughout the supply chain is key to comply with CBAM. Engaging with suppliers and clients helps to collaboratively manage the impact of CBAM across the supply chain.

Yes No Beginning readinessYour organisation is at the initial stage of CBAM compliance readiness. You should further build your knowledge and develop your processes. The first report was due on January 1, 2024 so it is important you start to act as soon as possible to reach future compliance. Speak with us to learn more. Advanced readinessYour organisation has taken important steps towards CBAM compliance. You are gathering necessary data and conducting preliminary assessments. Continued efforts and training will help you achieve full compliance and optimise your processes. Speak with us to learn more. Leading readinessYour organisation is well-prepared for CBAM compliance. You have the necessary data, and training in place, and are actively engaging with suppliers and clients regarding CBAM impacts. You are positioned to handle the regulatory requirements effectively and lead the way in compliance. Speak with us to learn more. Select your region: Australia Austria Belgium Bulgaria Croatia Cyprus Czech Republic Denmark Estonia Finland France Germany Greece HK/China Hungary Ireland Italy Japan Korea Latvia Lithuania Luxembourg Malta Netherlands Norway Poland Portugal Romania Singapore Slovakia Slovenia Spain Sweden Switzerland United Kingdom United States My region is not listed above

What next?

Contact information for your local CBAM specialist is provided to the right.

Talk to:

Email me

For more related content, check out our latest thought leadership.

Country Name Title Email address Image URL  (take from LinkedIn profile if there is no bio on pwc.com) Austria Daniela Stastny Partner, PwC Austria daniela.stastny@pwc.com https:http://pwc.zhutiblog.com/com/de/assets/contacts/daniela-stastny.jpg.pwcimage.200.252.jpg Belgium Giovanni Gijsels Partner, PwC Belgium giovanni.gijsels@pwc.com https://media.licdn.com/dms/image/C4E03AQEs9TaKxuDrZw/profile-displayphoto-shrink_800_800/0/1659522494055?e=1726099200&v=beta&t=9_N4F1jqL09b3M0eWZSabwaQNW6YayXvZplrw4Qee34 Bulgaria Albena Markova Partner, PwC Bulgaria albena.markova@pwc.com https:http://pwc.zhutiblog.com/com/bg/about-us/PwCBulgaria_AlbenaMarkova_2.jpg Croatia Oliver Brgan Senior Manager, PwC Croatia oliver.brgan@pwc.com https:http://pwc.zhutiblog.com/com/content/dam/pwc/hr/hr/kontakti/Oliver.jpg Cyprus Martha Lambrou Partner, PwC Cyprus martha.lambrou@pwc.com http://www.pwc.com.cy/en/theacademy/assets/pwc-academy-trainers-martha-lambrou.jpg Czech Republic Ales Reho Manager, PwC Czech 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From 1 October 2023 - quarterly CBAM reports are due (first report was due 31 January 2024).

From 1 January 2026 - Liable to prepare and submit annual CBAM reports. The requirement to buy CBAM certificates is suggested to be delayed from 2026 to 2027, giving importers more time to get ready. It’s important to note that the costs related to emissions included in imports from 2026 will still be applicable; they will just be accounted for in 2027. You will also need to determine if a credit for any local carbon pricing paid is available, which may be used to reduce the number of CBAM certificates required.   

Navigating the strategic landscape of CBAM to unlock sustainable growth Unlocking value through sustainable supply chain reinvention Embracing the challenges and opportunities presented by CBAM requires a comprehensive strategy for businesses aiming to align with evolving carbon emissions standards, and optimise their competitive edge in a carbon-conscious market.

At PwC, we understand the multifaceted challenges and opportunities CBAM presents to global businesses. Our dedicated team of advisors bring deep industry & supply chain knowledge and regulatory expertise to tailor solutions that not only achieve compliance with CBAM but also leverage it as a strategic asset. We don’t look at regulations like CBAM in isolation, instead we recognise the importance of aligning CBAM compliance with other regulatory requirements, such as the Corporate Sustainability Reporting Directive (CSRD) and EU ETS, finding synergies and unlocking value in the process. By harnessing advanced technologies and our global network of Alliance partners, we offer clarity and precision in navigating the complex data landscape of carbon emissions, transforming compliance into a competitive advantage.

Embracing CBAM goes beyond mere adaptation; it's about reimagining your business model in the context of a low-carbon economy. Our strategic approach focuses on:

Strategic planning and impact assessment Integration & transformation for sustainability Operational execution and support Strategic planning and impact assessment Legal and regulatory guidance to navigate the evolving landscape of CBAM, ensuring your business remains ahead of compliance obligations and leverages regulatory incentives. Comprehensive assessment of your current operations, supply chains, and product portfolios to identify direct impacts and opportunities for optimisation under CBAM regulations.

Integration & transformation for sustainability Integration of carbon management strategies with financial planning and risk management, enhancing resilience and uncovering new avenues for growth and innovation. Development of a roadmap for net zero transformation, aligning with CBAM's phased implementation to progressively reduce carbon intensity and costs associated with carbon pricing.

Operational execution and support Implementation of governance models and operational strategies that embed sustainability into the heart of your business, fostering a culture of innovation and environmental stewardship. Providing practical administrative support from local offices, facilitating smoother adaptation to CBAM requirements and ensuring consistent implementation across the regions worldwide.  [Find out more about PwC Net Zero Transformation Services]

“Carbon Border Adjustment Mechanisms, like the EU CBAM, are profoundly reshaping global supply chains. Businesses that understand this early and act decisively won’t just avoid unexpected costs; they’ll lead the way in building more resilient value chains..”

Renate de LangeEMEA Sustainability Leader, PwC Netherlands CBAM reporting accelerator Based on our experience in CBAM reporting and deep regulatory understanding, in combination with PwC’s capabilities of automatization, we are excited to introduce the global CBAM Reporter. This easy-to-use digital accelerator offers a guided solution for both importers as well as their suppliers. The accelerator can help you to:

Simplified process for data collection from suppliers A scalable solution that can support complex supply chains and provide better insight in the impact of CBAM on your business Automated data processing  Compilation of data for up-to-date CBAM reporting Reach out if you have any questions.

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Claudia Buysing Damsté

Partner, International Trade, Customs, Sustainable supply chains, PwC Netherlands

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