The Operators of Third Countries Installations (O3CI) Portal is live. Producers of CBAM goods can use it to upload their installation-specific data centrally and share it with EU importers as CBAM declarants. This new solution streamlines the data transmission process for producers and reduces data collection efforts for importers.
The challenge of sharing CBAM data
The new year starts with new requirements and IT-solutions in the EU Carbon Border Adjustment Mechanism (CBAM). These changes already affect the reporting obligations in the current transitional period for EU importers of CBAM goods.
From 1st January only CBAM methods will be recognized for the determination of emissions. This new requirement does not yet apply to the report for Q4 2024, which is due by January 31, 2025. Comparable methods can still be used this time, provided they are based on actual data from the manufacturing installations.
Until now, the exchange of these data from the producers of CBAM goods to EU importers has been a major challenge in corporate practice. The EU Commission had provided a communication template in XLS format to support this process.
The template ensures that all relevant emission components and precursors are covered in the calculation of the emission values for the installation. In addition, the template should also facilitate the exchange of data between producers and importers.
Where data is available, data collection and processing is a major effort. Producers have to provide data to a large number of buyers. Importers have to process data from these templates or other sources for application in their CBAM reports – if no software tools are in use.
A new portal in the CBAM Registry is now ready to help by streamlining the process of exchanging such data. The activation of the portal represents an important milestone in the implementation of the definitive CBAM IT-system.
Go-live of O3CI Portal
The Operators of Third Countries Installations (O3CI) Portal has been live since December 31, 2024. Via this portal non-EU producers of CBAM goods can upload installation-specific data. This data can then be shared with EU importers as CBAM declarants.
For non-EU producers
Status quo: Until now, non-EU producers (or suppliers) of CBAM goods have been facing numerous data requests from EU importers. Where software tools are in use, the same data may have to be entered into different interfaces or formats.
New: The O3CI Portal offers producers the following functions based on §10 of the CBAM regulation (2023/956):
- Registration as an installation operator in the EU CBAM;
- Centralized transmission of CBAM data about installations, emissions and carbon prices already paid (and their verification from 2026 onwards);
- Secure exchange of data with EU importers for their CBAM reports.
Necessary steps: To perform these functions, the following steps need to be taken by producers (see details in user manual):
- Register via an EU login to the O3CI Portal: The EU Commission manages access requests and registrations, which have been possible since January 1 and has published a guide for requesting access.
- Enter the required data about operator, installations, production routes, emissions and carbon prices already paid and updating these data (when needed);
- Select relevant EU importers for data disclosure via their EORI number.
For EU importers
Status quo: Importers manage a large number of data sources (mostly the above-mentioned XLS templates) through which they receive CBAM data from their suppliers. To add the required values to their CBAM reports, these data must be read out. This is done either manually or electronically through software tools.
New: From now on, EU importers have 3 options for transferring the required data to their CBAM report via the Declarant Portal in the Transitional CBAM Registry:
- Manual entering of data via the input masks or selection of existing data from the individually created operator or installation lists;
- Electronic upload of an XML file generated by software tools that automatically adds the data to the report;
- [NEW] Selecting installation-specific data from the O3CI registry – provided that such data has been added and linked to the importer’s EORI number.
Necessary steps: To use the data from the O3CI registry, the following steps are recommended to importers in the user manual of the declarant portal:
- Contact the producer to inform them about this new option to share data via the O3CI Portal and provide the EORI number for data disclosure;
- Verify the registration of the relevant installations in the O3CI and the linking of the emissions data with the EORI number;
- Add the CBAM goods in the corresponding section of the quarterly CBAM report and create the needed emissions entries;
- Select the operator, installation and production route from the O3CI registry;
- Enter the quantity of the imported goods from the selected installation and production route.
Once these steps have been completed, the emissions data is automatically populated in the emissions tab of the report and can no longer be edited. They are “read-only” and there is (so far) no option to derive such data from the Transitional Registry (e.g. via APIs).
Importers are still liable for the information in their CBAM reports – regardless of the data source selected. A warning message in the portal shows-up as a reminder. If the data provided appears to be incorrect or incomplete, the entry can be removed from the report and added manually or electronically.
Reduced data efforts
In the long term, this solution should significantly reduce the data efforts for both non-EU producers and EU importers. Importers, in particular, would benefit from a significant reduction in data collection work if the required emissions data can be directly accessed through the CBAM Registry.
However, it remains to be seen how this solution will be accepted by non-EU producers. Besides trust in data safety and confidentiality, the usability of the O3IC portal will be another factor.
It is also still unclear whether and how non-EU producers can record data from precursors via the O3CI Portal. For goods from complex value chains with multiple upstream suppliers, complete data for determining CBAM emissions is rarely available. In such cases, the O3IC portal may only be of limited help.
Even if data sharing via the O3IC portal can be much simplified, this does not reduce the effort required to monitor and calculate emissions data. However, such work is up to the producers. Importers can only make the availability of such data a purchasing requirement.
Importers will also need access to the latest data to calculate their CBAM certificates and costs from 2026. Here interfaces are required to not just have this data “be sitting” in the Registry, but feed into controlling tools and decision-making processes.
Sources and further information:
- European Commission: User Guide for Access Request in the O3CI
- European Commission: User Manual O3CI-Portal
- European Commission: User Manual for CBAM Declarant Portal
- EU: CBAM Implementing Regulation (2023/1773)
- EU: Regulation establishing CBAM (2023/956)
Photo by Mika Baumeister on Unsplash
