Access to the CBAM transitional registry is managed at the national level: in Germany, via the customs portal. Registration is only available since mid of January. Time is running. The first CBAM report must be submitted via the transitional registry already by the end of January. However, corrections are possible until the end of July.

Transitional registry for CBAM implementation

The CBAM transitional registry plays a central role in the CBAM administration for handling the reporting obligations in the transitional phase of the EU Carbon Border Adjustment Mechanism (CBAM).

The CBAM quarterly reports recording the embedded emissions of imported goods are to be submitted via this registry. Large parts of industry that import CO2-intensive goods are obliged to record comprehensive data as of October 2023.

From 2026, the transitional registry is to be transferred to the permanent CBAM registry, which will then also be used to administer the CO2-based import levy.

In addition, communication between the EU Commission, the national CBAM and customs authorities and importers is supposed to take place via this registry.

The CBAM transitional registry is set up as a standardised, secure, electronic database and is accessible via different portals. Importers can use the registry via the Trader Portal.

Get access to the registry

The German Emissions Trading Authority (DEHSt), who was appointed as the competent national CBAM authority at the end of the year, announced that access management for the CBAM transitional registry in Germany will take place via the Zollportal.

First, reporting declarants have to run through the registration process, which is only available since mid of January:

1. ELSTER account based on the tax number of the applicant.
2. business customer account in the customs portal.
3. Economic Operators Registration and Identification (EORI) number.
4. Registration in the EU Trader Portal and Identity Management service, CBAM portal.

A DEHSt statement says: “The delayed provision of the registration and thus the late possibility of preparing CBAM reports in Germany will not lead to the imposition of sanctions or other disadvantages for reporting declarants.”

It points out that corrections to submitted reports are possible until July 31, 2024. Sanctions will also only be imposed after a correction procedure has been initiated.

Even though the transitional registry was set up by the European Commission, access to it is managed at national level.

Access to the CBAM transitional registry is only possible for importers and indirect customs representatives as CBAM declarants subject to reporting obligations.

Using the CBAM registry

The CBAM transitional registry went online at the start of the CBAM transitional period in October. In a first online webinar on October 27, the EU presented the transitional registry and published a user manual (last update 22/12/2023).

Registry areas

Once the declarant profiles have been assigned, the following areas are available to registered importers in the transitional registry:

1. Profile: this is where the user profile and general information on the reporting declarant is managed.
2. Installations: The list of installations for the production of the imported goods with the corresponding entries is managed here. An operator is assigned to each installation.
3. Installation operators: The operators of the installations are registered and their data is administered here. 
4. Reports: Here the quarterly reports can be created, edited and viewed.

Data recording

The CBAM report is divided into 3 sections in which the quarterly data are to be entered:

1. Header section: Basic information on the CBAM declarant and the reporting period.
2. Imported goods: Information on quantities, countries of origin and destination areas in aggregated form per CN code.
3. Emissions of goods: Data on CO2 emissions and parameters for the installations and production methods used to manufacture the imported goods.

The hierarchical reporting structure follows the approach of customs declarations. The submission of supporting documents as attachments is possible.

Data for the quarterly reports can be filled in two ways:

1. Using the web-based user interface of the declarant portal.
2. Uploading a ZIP file containing the XML structure of the report together with the attachments.

Management of CBAM reports

The process of generating a CBAM report follows several steps:

1. Creation of a new report in the respective reporting period
2. Entering the report data or uploading the report files as XML
3. Validation of the entered report data
4. Submission of the report to the transitional registry
5. (if necessary) Amendment of the report only before submission deadline
6. (if necessary) Invalidation of report to submit a new report

After registration of a submitted report in the CBAM transitional registry, the review process by the EU Commission and the national CBAM authority starts, which may result in the report being corrected, litigated, discarded or finally accepted.

Little time for CBAM reports

With the deadline for submitting the first CBAM report approaching on January 31, 2024, importers have little time left to enter the data for the fourth quarter of 2023 in the transitional registry.

Manually entering the large amounts of data via the web-based interfaces in the transitional registry can be very time-consuming. Particularly in Germany, where access will not be available until shortly, this could pose major challenges for companies with large import portfolios.

However, all data can already be prepared now. If they are recorded in the structure and formats specified by the EU, they can then simply be uploaded to the registry without much effort once access is activated.

With the CO2 IQ CBAM Report Builder, you can systematically record the required mandatory data, have missing emissions data be completed automatically and get a XML files created for data transfer to the CBAM transitional registry. Contact us for further information.

(this blog is regularly updated – last update on January 22, 2024)

Sources and further information:

• DEHSt: Transitional Registry and CBAM-Portal for Companies
• European Commission: CBAM Transitional Registry
• European Commission: User Manual CBAM Declarant Portal
• EU: Implementing Regulation on Reporting Requirements
• EU: Regulation Establishing a Carbon Border Adjustment Mechanism
• Zoll: Access to the CBAM-Portal for Companies

Photo of Keith Kasaija on Unsplash