Compiled by ChamberCustoms - accurate at the time of publishing (July 2025)

Webinar Q&A Summary

Following our recent webinar, EU CBAM: Trader Responsibilities and Policy Developments, we’ve compiled answers to the most frequently asked questions from attendees.

Whether you’re already providing emissions data to EU customers or just starting to assess your exposure under the EU Carbon Border Adjustment Mechanism (CBAM) framework, the information below is designed to help you understand your obligations and prepare for the next phase of CBAM implementation.

Scope of CBAM and Covered Emissions

Does the EU CBAM include electricity? Also, does the transitional period end in 2025?

Yes, electricity is included in CBAM, although our session focused on goods. Electricity exports to the EU apply to only a small number of companies. CBAM currently applies only to Scope 1 (direct) emissions. The transitional period ends on 31 December 2025, with the definitive regime starting in 2026.

Do we report carbon from the distribution warehouse to the EU end user?

Emissions related to transportation are not included in CBAM. Only emissions embedded in the production of goods are reportable.

However, if you’re the exporter, you carry a commercial responsibility for providing emissions data of your product to your EU customer. Even if you didn’t produce the emissions, you’ll need to collect and pass on the relevant upstream data.

If this applies to your setup, we can support you with emissions data collection and supply chain mapping.

Our goods are manufactured in Italy, assembled in the UK, and then sold back to the EU. What emissions do I need to report?

During the transitional phase, only Scope 1 emissions are reportable. From 2026, certain indirect emissions may be added depending on the product.

Given that the product moves across multiple countries and stages, this will require careful data gathering from your EU supplier and the UK assembly stage. There are already agreements in place to ensure that the carbon tax is not paid twice.

We regularly support businesses with this type of cross-border scenario and can help ensure nothing is overlooked.

Supply Chain Complexity & Commercial Responsibility

We’re distributors exporting goods we bought from wholesalers who, in turn, bought from third-country manufacturers. How far back does verification go?

Emissions data must be obtained from the original manufacturer. While the legal reporting obligation lies with the EU importer, UK exporters are expected to provide verified emissions data as part of their commercial relationship.

Once verification requirements are confirmed, CBAM data provided to you will likely have to carry verification before it can be accepted as input in the UK. The data you add, or the calculations you carry out in the UK, will then need to be UK verified before then can be accepted in the EU.

We can help you establish the necessary verification chain and liaise with suppliers where required.

We do quarterly CBAM reports, but will likely fall under the small importer threshold - do we need to register?

If you're an EU importer, you may switch to an occasional declarant under the new de minimis rules. If you're a UK exporter, your role remains commercial, and you must provide your EU clients with accurate emissions data.

We export to our German entity but are also the importer of record. What’s our obligation?

If you are acting as the EU importer, you are responsible for submitting the CBAM report.

We can support you with EU-side filing and help you manage reporting across multiple business entities.

We use a forwarding agent to report CBAM emissions for goods to EU customers. Is that acceptable?

Yes. If you are the importer of record, for example, if you are selling under Delivered Duty Paid (DDP) Incoterms, where you take on responsibility for import duties and formalities, your agent can submit CBAM declarations on your behalf. However, you remain legally responsible for the accuracy of the submission.

We offer an integrated solution that works with your forwarding agent, or can step in directly if needed.

If we import into the EU, how do we find an EU-based declarant?

You’ll need to appoint a representative based in the EU, such as a customs agent, logistics provider, or tax representative.

ChamberCustoms works with a network of trusted EU partners and can support you in appointing a suitable declarant.

Reporting Process & Tools

What software is available to support CBAM mapping?

There are a few emerging tools, but most companies are currently using bespoke spreadsheets or carbon accounting platforms to manage CBAM data.

ChamberCustoms partners with CarbonGlance, a dedicated CBAM mapping and reporting tool that helps businesses track, calculate, and prepare emissions data in line with EU requirements. This tool is tailored to exporters’ needs and simplifies the process of collecting and managing upstream data.

Industry Trends & Customer Behaviour

Only two of our 300 EU customers are asking for CBAM data - is that normal?

Yes - this is common at the early stage of CBAM. Awareness and enforcement vary by country and sector. However, we expect a sharp increase in customer requests as the 2026 definitive regime approaches and non-compliance risks grow.

We can help you put scalable processes in place now, so you're prepared when customer requests increase.

Policy Developments and What’s Next

Will UK exporters receive an exemption before the definitive CBAM phase begins in 2026?

No exemption is currently expected. As highlighted in the webinar, while the UK and EU are in dialogue regarding linking their emissions trading systems, there is no agreed position. Exporters must not assume they will be exempt from providing emissions data or complying with EU CBAM obligations.

We monitor developments and provide timely guidance, helping you stay ahead of changes and maintain compliance.

What changes in reporting are expected from 2026?

From 2026, CBAM enters its definitive phase, meaning:

Verification becomes mandatory. You’ll no longer be able to simply provide figures; you must explain how they were calculated and ensure they have been verified.
CBAM certificates must be purchased by EU importers to account for the embedded carbon price difference.
The EU scheme operates on a certificate purchase model, whereas the proposed UK scheme (still in development) may follow a tax-like quarterly rate. While the systems are similar in principle, they are not yet aligned.

We help businesses prepare for verification by developing a compliant monitoring and reporting methodology. We use technology-backed tools to calculate emissions, produce documentation in the formats preferred by EU importers, and offer ongoing support.

Need Help? ChamberCustoms Can Support You

Navigating CBAM can be complex, but you don’t have to do it alone.

ChamberCustoms offers a dedicated CBAM Consultancy Package to support businesses with:

Emissions mapping, calculations and data collection
Preparing for verified reporting in 2026
Supply chain analysis
Support with EU-side filings
Customer communication templates

Whether you need one-off advice, hands-on support or training, we’re here to help.

Next Steps

If you're unsure how CBAM affects your business, would like to review your current approach, or need expert help calculating your embedded emissions, our team is here to support you. Here’s how you can get started:

Learn more about CBAM and your responsibilities
Visit our EU CBAM information page for a clear overview of what’s required and when.
Explore what’s included in our CBAM Consultancy Package
From emissions mapping and data collection to reporting tools and guidance, our consultancy package is designed to simplify CBAM compliance.
Find out more here
Take our free CBAM Health Check
Assess your readiness in under five minutes, and receive a personalised report.
Start the Health Check
Prefer to talk it through?
Book a free, no-obligation 30-minute discovery call with one of our consultants to explore your specific needs.
Book your call today