The path to CBAM applicant status: Why you should act now and what requirements you need to consider in order to obtain CBAM applicant status on time
published on
2.12.2024
The European Union's Carbon Border Adjustment Mechanism (CBAM) is one of the key instruments for promoting sustainable production and transparency of emissions in global supply chains. Since its introduction in October 2023, CBAM has been in a transition phase that will run until the end of 2025. After the end of the transition phase and with the start of full CBAM implementation in 2026, certification as a CBAM applicant will also become mandatory - a process that can take up to 180 days and should therefore be started early.
CBAM aims to minimize distortions of competition caused by different climate protection measures between the EU and other countries. By quantifying and monetizing the CO₂ emissions of imported goods, an incentive is created to make supply chains more sustainable. For companies, however, this means that they have to provide increasingly detailed information on the emissions of their products and preliminary products - a challenge that requires considerable adjustments, especially for small and medium-sized companies with limited resources.
Since August 2024, for example, only real data has been permitted for reporting, which increases the pressure on companies with regard to data quality and verification obligations. From 2026, external certification of this data will be mandatory, as will the purchase and submission of CBAM certificates.
In order to obtain CBAM applicant status, companies must fulfill specific requirements and go through a clearly defined registration process. These include:
These documents are submitted digitally via an electronic CBAM register and processing by the competent national authority can take up to 180 days. Missing documents or insufficient evidence can significantly prolong the process or lead to rejection of the application.
The CBAM transition phase offers companies the opportunity to gradually adapt their processes. Timely action minimizes risks such as legal sanctions and operational disruptions. SMEs in particular need a clear strategy to meet the growing requirements:
1. create transparency:
IdentifyCBAM-relevant products and suppliers and start collecting emissions data.
2. automate processes:
Digitaltools such as supplier relationship management (SRM) systems can help to standardize and simplify the collection, management and reporting of data.
3. avoid bottlenecks:
Sincethe application process can be lengthy, we recommend submitting your application early.
The implementation of CBAM-compliant data management can be facilitated by specialized software solutions. An SRM system such as the one from Tacto offers, for example:
The CBAM represents a considerable challenge for many companies, but at the same time offers the opportunity to make their own supply chains fit for the future. The transition period should be used intensively to implement the necessary adjustments and apply for applicant status in good time. Companies that act now not only ensure legal and operational stability, but also strengthen their competitive position.
The full application of the CBAM from 2026 will be characterized by strict controls and regular adjustments. In the future, additional sectors and products could be included in the scope of application, making the requirements for companies even more complex. At the same time, innovative technologies and data-based solutions for optimizing supply chains are expected to become even more important. Companies that act proactively will be able to benefit from this development and strengthen their market position.
Download the detailed guide to derive concrete recommendations for action for your company!
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