CBAM Q4 2024 Transitional Report: Step-by-Step Filing Guide

The Final Quarter of the CBAM Transitional Period

Q4 2024 (October-December 2024) represents a critical threshold in the Carbon Border Adjustment Mechanism (CBAM) transitional period. By this quarter, the use of default values is severely restricted, and importers must base their reporting on actual installation-level data. The Q4 2024 report must be submitted through the CBAM Transitional Registry by January 31, 2025 (Commission Implementing Regulation 2023/1773, Article 8).

This guide provides a step-by-step walkthrough of how to file the Q4 2024 report, what data is required, and how to avoid common errors.

Step 1: Accessing the CBAM Transitional Registry

The CBAM Transitional Registry is an online platform operated by the European Commission. To access it:

1. The importer must hold authorized declarant status from the competent national authority in the relevant EU Member State
2. Login via an EU Login account
3. The company's EORI (Economic Operators Registration and Identification) number must be registered in the system

Importers create a separate report for each quarter. For the Q4 2024 report, begin by selecting the relevant period under "Create New Report" (European Commission CBAM Transitional Registry User Guide, 2024).

Step 2: Entering Import Data

The following information is required for each CBAM-covered import transaction:

Mandatory Data Fields

• CN code: Combined Nomenclature code (8-digit)
• Country of origin: The country where the goods were produced
• Importer and exporter details: Trade name, address, identification numbers
• Quantity: Volume of imported goods (in tonnes)
• Customs declaration reference: Relevant customs transaction number

Product Categories

Sectors and CN codes covered by CBAM:

(Regulation 2023/956, Annex I)

Step 3: Calculating Embedded Emissions

This step constitutes the most technical part of the reporting process. Embedded emissions must be calculated for each imported item.

Calculation Methods

Method 1: Actual Emissions Data (Preferred)

Actual emissions data obtained from the producing installation is used. This method requires:

• Direct emissions from the installation (Scope 1): Fuel combustion, process emissions
• Indirect emissions (from electricity consumption): Electricity consumed x emission factor
• Production volume: Total production during the reporting period
• Embedded emission intensity: Total emissions / total production (tCO2e/tonne of product)

Method 2: Default Values (Restricted)

Since July 2024, default values may only be used for a maximum of 20 percent of total embedded emissions. Default values are average emission intensities published by the Commission on a country and product basis. Valid justification must be provided when actual data cannot be supplied (Commission Implementing Regulation 2023/1773, Article 4(3)).

Method 3: Equivalent National Method

If the mandatory monitoring system in the country of origin has been recognized as equivalent to the EU methodology, data from that system may be used.

Calculating Indirect Emissions

Indirect emissions (from electricity consumption) are mandatory particularly for steel and aluminium. The calculation:

Indirect embedded emissions = Electricity consumed (MWh) x Emission factor (tCO2/MWh)

The grid emission factor for the country of origin or a supplier-specific value may be used.

Precursor Emissions

For complex products, the embedded emissions of inputs (precursors) used in production must also be accounted for. For example, the emissions of hot-rolled steel used in steel pipe production must be included in the final product's embedded emissions (Commission Implementing Regulation 2023/1773, Annex III).

Step 4: Declaring Carbon Prices Paid in the Country of Origin

While no financial obligation exists during the transitional period, any carbon price paid in the country of origin must be declared. This information forms the basis for deductions to be applied during the definitive phase:

• Amount paid under a carbon tax or emissions trading system
• Name of the mechanism under which payment was made
• Unit price (national currency/tCO2e)

Since Turkey does not yet have an operational emissions trading system, Turkish-origin products typically declare "no carbon price paid" in this field.

Step 5: Reviewing and Submitting the Report

After all data has been entered:

1. Consistency check: The Registry automatically checks the consistency of entered data
2. Review warnings: Warnings generated by the system should be examined and corrections made where necessary
3. Report approval: Electronic approval by the authorized person
4. Submission: Electronic transmission to the competent national authority

Corrections may be made within 30 days of submission. After this period, the national authority must be contacted for amendments.

Common Errors and Solutions

Error 1: CN Code Mismatches

Problem: Incorrect or incomplete CN code usage is the most common error type.

Solution: Cross-check CN codes from customs declarations against CBAM Annex I. Confusion among sub-items is particularly frequent for steel alloys.

Error 2: Exceeding the Default Value Limit

Problem: Default value usage exceeding the 20 percent threshold.

Solution: Contact suppliers urgently for items where actual data has not been collected. Prepare valid justification for the Commission where actual data cannot be provided.

Error 3: Omitting Precursor Emissions

Problem: Failure to account for precursor emissions in complex products.

Solution: Map all inputs in the production process and calculate the embedded emissions of each precursor separately.

Error 4: Indirect Emission Calculation Errors

Problem: Using incorrect emission factors or omitting indirect emissions entirely.

Solution: Use the current grid emission factor for the country of origin. Reference data published by the IEA or national energy agencies.

Preparation Perspective for the Definitive Phase

The Q4 2024 report, as one of the final quarters of the transitional period, serves as an important rehearsal for the definitive phase (January 1, 2026). While preparing this report, also:

• Standardize data collection processes
• Establish supplier communication protocols
• Develop internal audit mechanisms in preparation for verification processes
• Document your emission calculation methodology

Key Dates

Reminder: Although no financial obligation exists during the transitional period, incomplete or inaccurate reporting may result in administrative penalties. The European Commission has recommended that Member States apply effective and dissuasive penalties even during the transitional period (European Commission CBAM Guidance Document, 2023).