Compliance Briefing — April 10, 2025

Executive briefing: During the CBAM transitional phase, importers of cement, iron and steel, aluminium, fertilisers, electricity, and hydrogen must submit Q1 2025 reports by April 30, 2025 via the Transitional Registry. Reports must capture embedded direct and indirect emissions, default value adjustments, and verified production routes for each consignment.

Key compliance checkpoints

Data completeness. Ensure suppliers provide production site identifiers, technology descriptions, and emission factors enabling the CBAM emissions formula.
Default value limits. Apply default values only where primary data is unavailable, documenting justification and updates promised by 2026.
Account governance. Maintain authorised declarant accounts, role-based access, and segregation of duties for submission and approval.

Control alignment

Integrate with ETS and ESG reporting. Align CBAM datasets with EU ETS records, Scope 3 inventories, and CSRD climate disclosures to avoid inconsistencies.
Supplier contracts. Update purchase agreements with clauses requiring timely emissions data, verification statements, and audit rights.
Systems automation. Leverage customs and ERP integrations to populate CN codes, quantities, and emission factors directly into the Transitional Registry templates.

Enablement moves

Schedule pre-submission reviews with sustainability and tax teams to validate calculations and supporting evidence.
Build variance dashboards comparing prior quarters, highlighting drivers such as product mix or supplier changes.
Prepare remediation plans for data gaps, including escalation paths to suppliers and fallback estimation methodologies.

Sources

Zeph Tech streamlines CBAM reporting with supplier data pipelines, emissions calculators, and governance dashboards so importers meet the April 2025 deadline without disruption.