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Carbon+Alt+Delete aims to assist importers in reporting the quantity of imported goods and emissions data for imported goods under CBAM. We don't currently support carbon pricing, verification or other administrative steps in our software. We believe that the main added value of using our tool is that you need to do your corporate carbon footprint anyway, and then you can make the best use of the information available. In this sense, we are not a dedicated CBAM tool. To be completely transparent, we believe that its scope is too limited and that our proposed use of our carbon engine already provides an answer to most needs related to CBAM.
These reporting metrics will anyway be part of your Scope 2 'Electricity' or Scope 3.1 'Purchased Goods & Services' of your corporate carbon footprint in our carbon engine. However, please note that the emissions included in our calculation engine are GHG Protocol compliant and therefore take into account full life cycle emissions for Scope 3.1. The embedded emissions of imported goods for CBAM only need to take into account direct emissions and indirect emissions from electricity and precursors ('Tier 1') and therefore not the full life cycle. In addition, from the final stage onwards, only direct emissions need to be reported. Simply put, if you were to use the embedded emissions from our calculation engine, you would be including more emissions than CBAM strictly requires.
However, you should try to obtain accurate emissions data from your suppliers. Until July 2024, you can estimate as much embedded emissions as you need using the JRC's default values for the specific embedded emissions factors (see document below). After that, they can only use these values to estimate up to 20% of their total imported embedded emissions.
However, we believe that you can use our calculation engine to gain insight into the embedded emissions of your imported goods and use it to achieve compliance for your CBAM reporting, both during the transitional and final phases. We will show you how, using the step-by-step guide below.
Step 1. Calculate your corporate carbon footprint
· Request both activity (number of goods imported) and emissions data from your suppliers using our 'Request' functionality. Make sure you do this in accordance with the GHG Protocol.
Step 2. Label your CBAM goods
· Use the 'Custom fields' functionality to label the inventory lines you want to report for CBAM. We suggest that you label at three levels, you will need to create these custom fields yourself.
- CBAM commodity class (e.g. tag with ‘CBAM cement’)
- During the transition period you will need to report per quarter, but your reporting period for your corporate carbon footprint is likely to be per year (e.g. tag with ‘Q1’).
- Whether it is based on supplier data (e.g. tag with ‘primary data' and ‘secondary data’).
Step 3. Export the inventory and analyse the data.
· Check if the supplier data accounts for more than 20% of your total embedded emissions by
· Check the difference between the GHG Protocol defaults and the CBAM defaults and adjust where necessary.
Step 4. Apply this information to your CBAM (out-of-scope of this support)
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