Urgent: The '20% Rule' Trap Closing July 2024

Did you rely on the Commission's default values for your last quarterly report? That safety net is gone. As of July 1, 2024, the rules have changed drastically.

The 20% Hard Limit

For complex goods (like steel screws, aluminum structures, or pre-fabricated cement products), you must now obtain actual emission data from your suppliers for at least 80% of the embedded emissions. This isn't a suggestion—it's a regulatory requirement.

What Counts as "Complex Goods"?

Complex goods are products that contain multiple input materials that themselves fall under CBAM categories. Examples include:

• Steel screws (steel + manufacturing emissions)
• Aluminum window frames (aluminum + processing)
• Pre-cast concrete panels (cement + aggregates + steel rebar)
• Fertilizer blends (multiple nitrogen compounds)

The Penalty Structure

Reports failing this check are considered "incorrect/incomplete," exposing you to penalties ranging from €10 to €50 per tonne of unreported emissions.

Your Action Plan

You need to engage your non-EU suppliers today using the official Communication Template. If they can't provide data, you must document your attempts to avoid fines.

1. Audit your current data sources - Identify which suppliers are providing actual data vs. where you're using defaults
2. Send the EU Communication Template - Use the official format that suppliers recognize
3. Document everything - Keep records of all outreach attempts, even if suppliers don't respond
4. Use supplier portals - Tools like Import Safe-Pass automate this collection process