Measuring exposure to the Carbon Border Adjustment Mechanism

Steps for measuring CBAM exposure

• Products and volumes exported.
• Annex I benchmarks and coverage check.
• Availability of embedded emissions data.
• Requests from European importers.
• Effect on price and competitiveness.
• Exposure level: in particular rating from 1 to 5.
• Finally, preparation plan, summary and references.

When to assess CBAM exposure

The checklist serves first on receipt of a data request from a European importer. It also serves when export prices are revised. Furthermore, it prepares an emissions measurement plan.

Industrial exporters are in particular its intended readers. The document also concerns sales, finance and environment departments.

Instructions for use

The checklist is first completed for each exported product, on the basis of its tariff heading. Coverage is then checked against Annex I. Furthermore, the exporter assesses the availability of emissions data site by site. Finally, the exposure level, rated from 1 to 5, determines the priorities of the preparation plan.

Expected outcome

At the end of the checklist, the exporter knows the products covered and its exposure level. Missing data are clearly identified. Consequently, responses to European importers and pricing policy rest on a documented assessment rather than on estimates.

Key facts

Limitations

The checklist does not calculate embedded emissions. In addition, only the consolidated version of Annex I is authoritative for coverage.

Further reading: investment project structuring; European Commission – Carbon Border Adjustment Mechanism.