FAQ on Emissions Trading

Our specialist manager David Kroll will be happy to answer any questions you may have about our greenhouse gases/emissions trading services.

Detailed explanations of frequently asked questions (FAQs) about emissions trading can be found on the website of the German Emissions Trading Authority (DEHSt).

In our download area, we offer our newsletter and various documents on greenhouse gases and emissions trading for download.

The authority responsible for customs declaration of the goods is also responsible for the purchase and surrender of CBAM certificates. This is either an importer established in the EU or, if the importer is not established in the EU, an indirect customs representative appointed by the importer. These are referred to in the Regulation as ‘CBAM declarants’ (see also ‘CBAM-relevant actors’).

A CBAM declaration contains information on the imported goods and the associated ‘grey emissions’ (see also ‘What are grey emissions?’).

The goods must be listed by type, quantity and country of origin.

In particular, the following must be specified:

• the quantities imported per good,
• the total emissions and the emissions per tonne per type of good,
• any CO₂ price already paid in the country of origin.

The term ‘grey emissions’ is used differently in different industries. In the CBAM context, it refers exclusively to CO₂ emissions generated during the manufacture of an imported product.

These include:

• direct emissions from the production process (e.g. from fuels)
• indirect emissions from the electricity used
• for certain products, additional emissions from raw materials

The regulation distinguishes between two types of goods:

Simple goods
Simple goods are products whose manufacture requires only raw materials and fuels that do not themselves contain grey emissions. In this case, emissions arise exclusively from the actual manufacturing process.
Examples include very basic industrial products without upstream production chains.

Complex goods
Complex goods are all other goods. Their manufacture must also take into account the grey emissions of the raw materials used – i.e. emissions from upstream production stages. This applies in particular to products with multi-stage supply and production chains.

Detailed calculation formulas can be found in the EU Implementing Act.

Further information is available on the EU CBAM legislation page.

Where possible, the actual emission values in the country of origin should be determined for the calculation of emission quantities. This includes information on the production facility, the goods themselves (CBAM goods group, customs tariff number, etc.) and information on grey emissions.

If these are not available, standard values based on literature and average values for the respective exporting country may be used. These standard values correspond to the average emission intensity of the exporting country and include a proportional surcharge for each type of goods.

If this is also not possible, alternative standard values are used. These are conservatively estimated standard values from the EU ETS installations.

Specific details from the European Commission can be found in the Implementing Act.

Note: The use of your own verifiable emission data is generally advantageous, as standard values are conservatively estimated.

If the manufacturer has already paid a CO₂ price for emissions in the third country, this will be taken into account in the CBAM. However, the amount credited cannot be higher than the price of a CBAM certificate in order to avoid double taxation.

With shares of free ETS 1 certificates, the price of CBAM certificates remains comparatively low. These free certificates will be gradually reduced and are set to be completely abolished by 2034. This means that the price of CBAM certificates will increase step by step.

Switzerland, Norway, Iceland and Liechtenstein are exempt from CBAM because they are already fully or closely linked to the EU emissions trading system.