Policy Briefing — July 3, 2025
EU CBAM declarants must submit the Q2 2025 transitional report by 31 July with verified emissions factors, third-country plant data, and governance evidence ahead of the 2026 certificate regime.
Executive briefing: Regulation (EU) 2023/956 keeps the transitional CBAM regime in force through 2025, obligating authorised declarants to lodge quarterly reports within one month of period-end. The Q2 2025 report covering April–June imports of iron, steel, cement, aluminium, fertilisers, electricity, and hydrogen is due July 31, 2025. Declarants must consolidate direct and embedded emissions, carbon prices paid abroad, and production-route metadata into the Commission’s CBAM Transitional Registry, maintaining auditable lineage between supplier submissions and customs declarations.
Data integration checkpoints
- Primary data ingestion. Capture installation-level emissions from supplier attestations using the Commission’s XML/CSV template, flagging gaps that must revert to default values under Implementing Regulation (EU) 2023/1773.
- Attribution logic. Harmonise Harmonised System (HS) codes, customs values, and carbon pricing claims inside data warehouses so sustainability analysts, trade compliance, and finance leads work from a single reconciled dataset.
- Metadata governance. Tag every CBAM line item with verification status, emission-factor source, and adjustment history to withstand Member State spot checks that can levy €10–€50 per tonne penalties for deficient reports.
Platform actions
- Registry interface controls. Enforce dual approval, credential rotation, and automated receipt archiving for uploads to the CBAM Transitional Registry, mapping confirmations back to enterprise data lakes.
- Scenario analytics. Model 2026 certificate purchase liabilities using Q2 intensity baselines, giving treasury teams insight into the cash impact once transitional reporting sunsets.
- Supplier enablement. Deploy supplier portals, validation rules, and multilingual training so upstream facilities can deliver timely actual emissions data instead of default factors.
Sources
- Regulation (EU) 2023/956
- Commission Implementing Regulation (EU) 2023/1773
- European Commission CBAM Guidance
Zeph Tech aligns CBAM data pipelines by stitching supplier emissions evidence, customs records, and finance analytics ahead of the July registry deadline.