26 June 2024
As the implementation of the EU Carbon Border Adjustment Mechanism enquiries gather pace, British Marine is receiving more enquiries about this new border requirement and how UK businesses can provide the relevant data to their EU-based customers.
The initial list of sectors includes those in which marine components may fall, such as aluminium and steel products, and precursors falling within the following HS and CN codes:
- 7305 – 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.
- 7318 – Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles of iron or steel.
- 7326 – Other articles of iron or steel.
- 7608 – Aluminium tubes and pipes.
- 7616 – Other articles of aluminium.
Your EU customers will need to begin reporting greenhouse gas emissions on your exports in scope of the EU CBAM on a quarterly basis from 1st October 2024. The EU importer (or ‘reporting declarant’) must provide a ‘CBAM report’ on a quarterly basis, to the European Commission via the CBAM Transitional Registry, by the end of the month following the end of the quarter. However, EU importers may ask you for information to help them calculate the embedded emissions of the products you export to them. UK exporters may wish to speak to their importing counterparts to understand what information importers need in order to meet their CBAM obligations.
Information requests may also be directed to UK producers whose products are purchased by clients who themselves manufacture CBAM goods, and products may serve as ‘precursor’ for their CBAM goods, which are subsequently exported to EU countries. Also, if you sell your products to traders who then sell them to EU customers, your goods may fall under the CBAM.
The European Commission has defined relevant precursor materials as simple or complex goods which have embedded emissions, and which are identified as being within the system boundaries for the calculation of embedded emissions of a complex good.
British Marine has created guidance for its members on this new Border requirement within our new Decarbonisation Hub which can be found here.
