What do you need to know?
The French authorities recently announced, in an official statement, that importers may continue using default values in their Carbon Border Adjustment Mechanism (CBAM) declarations for the third and fourth quarters of 2024, under specific conditions.
This exceptional allowance is particularly beneficial for businesses facing difficulties in obtaining accurate CO2 emissions data from their supply chains. While the continued use of default values provides flexibility, it comes with the expectation that importers will actively seek to obtain precise CO2 emissions data going forward.
The French government also clarified that importers must be able to demonstrate that they have formally requested actual CO2 emission values between each reporting period.
This requirement ensures transparency and prevents businesses from relying indefinitely on these provisional figures.
Key requirements for importers
Continue requesting accurate
CO2 emissions date
Though default values are permitted for the time being, importers are strongly advised to work closely with their suppliers to secure accurate CO2 emissions data.
Proactively gathering these figures now will ease the transition when the use of default values is no longer allowed.
Submit your CBAM
declarations in time
Meeting the reporting deadlines is critical. CBAM declarations for Q3 2024 are due by 31 October 2024, and for Q4 by 31 January 2025.
If you’re using default values, ensure you have documentation showing that you’ve formally requested accurate CO2 emissions data from your suppliers. Timely compliance is essential to avoid penalties and audits.
What are the consequences of non-compliance?
French authorities have signalled their intent to increase compliance checks. Companies that fail to submit declarations, or that use inaccurate or unjustified default values, risk severe penalties.
These may include substantial fines and the potential inability to obtain the status of CBAM declarant by 2026, which would significantly hinder their ability to trade under CBAM regulations in the future.
What does this mean for you?
The extension of default values offers short-term flexibility for importers, but it underscores the importance of adhering to reporting requirements and striving to obtain accurate emissions data.
With the increased scrutiny from authorities, it’s crucial that businesses remain compliant, particularly those relying on default values.
RM Boulanger is here to support you in managing these obligations and ensuring your business remains compliant.
